Articles and Blogs

The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently issued Advisory Opinion No. 23-15 (“Advisory Opinion”), a favorable opinion involving a consulting firm’s (“Requestor”) proposal to offer gift cards to its existing physician practice customers for referring potential new customers. The OIG approved the Proposed Arrangement (defined below), noting... READ MORE

The Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services found that most skilled nursing facilities (“nursing homes”) in Georgia that it surveyed are not correctly complying with life safety requirements or emergency preparedness requirements. OIG recently issued a report on its audits of life safety requirements or emergency... READ MORE

On December 14, 2022, the Office of Inspector General (“OIG”) issued an advisory opinion which approved a hospital program (“Arrangement”) to provide advanced practice provider (“APP”) support for inpatients being cared for by primary care physicians (“Participating Physicians”). Several months later, in May 2023, the Department of Justice (“DOJ”) reached a settlement of $29,744,065... READ MORE

On September 2, 2022, the Office of the Inspector General (“OIG”) published a study assessing potential Medicare program integrity risks related to the proliferation of telehealth services during the first year of the COVID-19 pandemic. OIG identified 1,714 providers with billing practices deemed “high risk” to the Medicare program. These providers billed approximately 500,000... READ MORE

OIG recently issued an advisory opinion related to a request by an ophthalmology practice (“Practice”) to examine four proposed funding arrangements for a continuing medical education (“CME”) program offered to local optometrists on current treatment and medication protocols for patients requiring ophthalmic surgeries. The CME program would offer 2-6 hours of CME, valued at... READ MORE

In December 2021, the Office of Inspector General (“OIG”) of the Department of Health and Human Services published an Issue Brief titled “Medicare and Beneficiaries Pay More for Preadmission Services at Affiliated Hospitals Than Wholly Owned Settings” (“Brief”)(available here). The Brief discusses Medicare’s policy to bundle (or not separately pay) certain services provided by... READ MORE

Reimbursement under the new Patient Driven Payment Model, staff background checks, infection control programs, facility-initiated transfer or discharge of a resident and the use of psychotropic drugs are several new skilled nursing facility (“SNF”) areas of audit and focus of Department of Health and Human Services Office of Inspector General (“OIG”). OIG publishes updates... READ MORE

Tuesday, May 26 Update Our Federal Advocacy Team is dedicated to providing frequent COVID-19 updates as they develop. Going forward, these updates will be distributed as developments warrant instead of nightly. These updates along with other resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website​. Note – ​we believe this is... READ MORE

Monday, May 11 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ OIG Updates FAQs on Administrative Enforcement Authorities on COVID-19 Arrangements OIG updated... READ MORE

Monday, April 6 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ Congressional Outlook The House and Senate remain in recess until at least... READ MORE