OIG Reports Recent Self-Disclosure Cases.
The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently reported several self-disclosure cases that were resolved in early 2017. In each case, the OIG alleged that the entity violated Civil Monetary Penalties Law (CMP) provisions.
The OIG reported the following cases:
- Quest Diagnostics, Inc. (Quest), of New Jersey, agreed to pay $1,151,053.07 for several alleged violations of the CMP. Quest phlebotomists allegedly performed services at several locations that were outside the scope of their employment. Further, the OIG alleged that Quest failed to adequately document and support their donation of valuable electronic health records software or information technology and services through donation agreements with certain referral sources. Further, Quest allegedly failed to collect second-year payments from physician clients in a timely manner, as required in electronic health record donation agreements.
- Athena Orchard View LLC, of Rhode Island, agreed to pay $61,576.22 for allegedly employing an individual that it knew or should have known was excluded from participation in federal health care programs.
- Metro Health Corporation, of Michigan, agreed to pay $2,305,743.39 for allegedly paying two independent contractor physician groups compensation that was in excess of fair market value.
- OhioHealth Corporation, of Ohio, agreed to pay $231,277.60 for allegedly employing three individuals that it knew or should have known were excluded from participation in federal health care programs.
- Health Services, Inc., of Alabama, agreed to pay $10,000 for allegedly employing two individuals that it knew or should have known were excluded from participation in federal health care programs.
- Ridgeview Institute, Inc., of Georgia, agreed to pay $29,113.82 for allegedly employing an individual that it knew or should have known was excluded from participation in federal health care programs.
- Ocean Dental of Arkansas, PC, agreed to pay $17,346 for allegedly employing an individual that it knew or should have known was excluded from participation in federal health care programs.
- Staten Island University Hospital (SIUH), of New York, agreed to pay $1,132,489.61 for knowingly submitting alleged false claims to Medicare. The claims were for walk-in and home-drawn lab services that SIUH knew or should have known were false because they lacked sufficient documentation in one or more of the following areas:
- A signature or adequate medical documentation supporting the physician’s intent to have the lab test performed;
- A date of request for lab services to be performed; and
- A physician’s order directing collection of the specimen in a patient’s home.
- Planned Parenthood Great Plains and Comprehensive Health of Planned Parenthood Great Plains, of Kansas, agreed to pay $18,808.92 for allegedly submitting claims to Medicaid where:
- Advanced registered nurse practitioners (ARNPs) provided the services yet billed improperly under a supervisory physician’s name and national provider identifier; and
- ARNPs were not properly enrolled or credentialed under Medicaid yet billed improperly under a supervisory physician’s name and national provider identifier.
- Joseph Hospital, Breese, of the Hospital Sisters of the Third Order of St. Francis (SJHB), of Illinois, agreed to pay $421,692.35 for allegedly submitting false or fraudulent claims to federal health care programs. The OIG alleged that SJHB knowingly submitted claims for items or services that it knew or should have known were not provided and were false or fraudulent. Allegedly, two independent and affiliated contractor physicians improperly allowed clinical staff to use:
- Signature stamps on physician order forms;
- Pre-signed physician orders; and
- Physician orders signed by clinical staff on their behalf with their knowledge.
The OIG Report is available at: