What Nursing Facilities Can Do to Implement a Compliance Program
Many nursing facilities have yet to develop and implement an effective compliance program, despite the fact that the Department of…
Office of Inspector General’s Sanctions And Exclusions of Healthcare Parties
During my term as Inspector General at the Department of Health and Human Services (HHS), I instituted what is now…
New Problems With GSA Debarment System
The General Services Administration (GSA) sanction screening database continues to have problems for users. The GSA debarment list, previously known…
Medicaid Sanction Screening
“To obtain/maintain active enrollment status, providers may not employ or contract with individuals/entities excluded from participation in any federal health…
Challenging Overpayment Extrapolations: Statistical Considerations
The government has recovered a record-breaking $10.7 billion in recoveries of health care fraud in the last three years, and contractor reform…
A Dozen Reasons to Not Like the GSA Debarment List
I don’t like the General Services Administration (GSA) debarment list. It provides mostly useless information with very little return on…
OIG’s Updated Provider Self-Disclosure Protocol: Sampling and Overpayment Extrapolation
On April 17, 2013, the US Department of Health and Human Services (HHS) Office of the Inspector General (OIG) released an Updated OIG’s…
Meeting the Challenge of Adequately Addressing Numerous Compliance Risks
Health care organizations are confronted by a vast array of complicated compliance risks. Although risk issues and areas are often defined by…
The OIG on Screening Against the GSA EPLS
“To obtain/maintain active enrollment status, providers may not employ or contract with individuals/entities excluded from participation in any federal health…
Compliance Policies and Procedures: The Ultimate Guide
Compliance policy and procedure documents are the foundation of any compliance program, both in terms of organization and management of…
Deficit Reduction Act Mandates Education on Fraud and Whistleblowers
On February 8, 2006, the Deficit Reduction Act of 2005 (DRA) was signed into law. Chapter 3 of Title VI specifically focuses…
Clinical Research and the Sunshine Law: Will the Government Publish Your Name?
Currently, two regulatory events are traveling along side of each other, but not yet intersecting. That will change next year. The two regulations…