Category Archives: Anti-Kackback

DHHS IG, Daniel Levinson Advises at HCCA that Fraud Enforcement Recovers 7 Dollars for Every Dollar Spent

Posted on May 4, 2012 by | Comments Off

Daniel R. Levinson, the Inspector General of the U.S. Department of Health and Human Services (“OIG’”) gave a keynote presentation at the Health Care Compliance Association’s 2012 Compliance Institute this past week.

The presentation was full of interesting details and issues relating to how the OIG and IG Levinson approach fraud and abuse enforcement. Below are some highlights of IG Levinson’s presentation.

The OIG’s ROI

IG Levinson reminded the audience of the significant return on investment the government gets from its fraud fighting efforts. According to IG Levinson, the government now recovers an average of 7 dollars for every dollar spent on its fraud fighting efforts. In his discussion, he pointedly remarked on how these statistics continue to show the significance of fraud in the health care system. Continue reading →

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Posted in Anti-Kackback, Compliance Programs, DHHS, Exclusion, Fraud and Abuse, General, Health & Human Services, Health Care, Health Care Providers, Medicaid, Medicare, OIG, Regulation, Regulatory Compliance

Lifewatch Services, Inc. enters into $18.5 Million Settlement and CIA to resolve False Claims Act Allegations

Posted on April 18, 2012 by | Comments Off

Lifewatch Services, Inc., an Illinois-based company, recently agreed to pay the United States $18.5 Million to resolve False Claims Act allegations filed by two separate whistleblowers. In addition to the settlement, Lifewatch entered into a comprehensive Corporate Integrity Agreement with the Office of Inspector General.

The whistleblower complaints alleged that Lifewatch improperly billed Medicare for ambulatory cardiac telemetry (“ACT”) services. Continue reading →

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Posted in Anti-Kackback, Compliance Programs, Corporate Integrity Agreements, DHHS, Diagnostic Testing, Fraud and Abuse, Health & Human Services, Health Care, Medicare, Ohio, OIG, Program Integrity, Regulatory Compliance, Settlements, Washington

Health Care Provider – Vendor Agreements: Have you looked at them lately?

Posted on March 9, 2012 by | Comments Off

Health care providers enter into agreements with vendors on a daily basis. Providers have agreements with suppliers for items and services, such as – durable medical equipment, medical supplies, EKG/Holter monitoring services and pharmaceuticals. Providers also have agreements with ancillary providers, like rehabilitation therapists, audiologists, psychologists, wound care professionals, and others.

Entering into and working with these types of agreements and arrangements can and does become a routine function of any provider. Often when providers treat these agreements as a routine day to day function, important compliance and business related concerns can get overlooked. An important element of the compliance function of any provider organization should include a periodic review of its vendor agreements and arrangements. Continue reading →

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Posted in Anti-Kackback, Compliance Programs, Exclusion, Fraud and Abuse, Health & Human Services, Health Care, Health Care Providers, HIPAA, Medicaid, Medicare, OIG, Regulatory Compliance, Self-Referral

Summary of OIG Advisory Opinion 11-18

Posted on December 15, 2011 by | Comments Off

On November 30, 2011, the OIG issued a favorable Advisory Opinion, No. 11-18, concerning a proposed arrangement that would facilitate the electronic exchange of information between health care practitioners, providers, and suppliers (the “Proposed Arrangement”).  Although, the Proposed Arrangement potentially implicates the Anti-Kickback Statute and includes a per-click fee arrangement, the OIG advised that it would not subject the data management company (the “Requestor”) to administrative sanctions under the Anti-Kickback Statute. Continue reading →

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Posted in Anti-Kackback, Fraud and Abuse, Health Care, OIG, OIG Advisory Opinions, Physicians, Regulatory Compliance