The COVID-19 pandemic continues to take a bite out of the volume of OIG enforcement action. All major metrics were down again in FY 2021, albeit at a less dramatic rate than in FY 2020. That’s one of … [Read more...]
OIG
OIG Makes Changes to Self-Disclosure Protocol for Overpayments
December 14, 2021
What would you do if you discovered that your lab inadvertently received Medicare payments to which it wasn’t entitled? Almost as a reflex, the answer to that question should involve consideration of … [Read more...]
Anti-Kickback
OIG Revises Self-Disclosure Protocol
December 1, 2021
On Nov. 8, the OIG did something it hadn’t done since 2013: It revised the Provider Self-Disclosure Protocol. Here’s a look at the six key changes to the protocol, which now has a new name, the Health … [Read more...]
Antikickback Statute:
OIG Green Lights Potential “Reverse Kickback” Compensation Arrangement
November 24, 2021
On Nov. 5, the OIG issued Advisory Opinion 21-15, signing off on a compensation arrangement between a practice and part-time nurse that raised issues of liability for reverse kickbacks. Here’s a look … [Read more...]
Compliance Alert
OIG Calls on CMS to Recover Phlebotomy Travel Allowance Overpayments
September 23, 2021
If your lab bills Medicare for phlebotomy travel allowances, a Medicare Administrative Contractor (MAC) claims audit may be in your future. The threat stems from a new Office of Inspector General … [Read more...]
Labs in Court
Medical Group Pays $94.4K to Settle HDL Process and Handling Payment Anti-Kickback Law Charges
September 23, 2021
Case: A physician and his Texas medical group have agreed to fork over $94,440 to the OIG for accepting kickbacks from now defunct Health Diagnostic Laboratory, Inc. (HDL) in the form of processing … [Read more...]
Enforcement Trends
Federal False Claims Act Recoveries Hit 5-Year High
August 26, 2021
For more than a decade, enforcement of the federal false claims act was a government cash cow. But in recent years, investment returns on the activity actually declined. That trend came to an end last … [Read more...]
Kickbacks
OIG Sheds Light on When Price Reductions Must Meet Discounts Safe Harbor
August 23, 2021
Labs that offer discounts of any kind to referring physicians run the risk of liability under the Anti-Kickback Statute (AKS) and other federal laws. However, new OIG Advisory Opinion No. 21-06 gives … [Read more...]
Enforcement
Fraud Recoveries Grow as Feds Target Telemedicine and COVID-19 Add-On Test Scams
July 29, 2021
Despite the COVID-19 pandemic and continued sequestration of enforcement funds, the federal Health Care Fraud and Abuse Control Program (Program) reversed recent trends and recovered more money in FY … [Read more...]
BILLING
OIG Work Plan Targets Medicare Part B Billing & Payment of Lab Tests
June 28, 2021
During the Public Health Emergency (PHE), the Department of Health and Human Services (HHS) has cut labs extraordinary slack in the form of waivers that temporarily loosen Medicare test coverage rules … [Read more...]
