Monthly Archives: March 2012

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

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

OIG Compliance Materials Consolidated on the Web

The Office of the Inspector General (“OIG”) has just consolidated the compliance education materials on their website at Compliance 101.  This section of the OIG’s website consolidates general educational materials, provider compliance videos and audio podcasts and general discussion.  Links to provider education for health care boards and physicians are included.  This can be a valuable resource for health care providers in developing and strengthening their compliance programs.

You can find the consolidated materials here —> OIG Compliance 101

OIG Reminds CMS, again, of Requirements to Implement Intermediate Sanctions for Home Health Agencies

On March 2, 2012, the DHHS OIG’s office of Evaluations and Inspections (“OEI”) released an early alert memorandum report related to its ongoing study of Survey and Certification of Home Health Agencies (OEI-06-11-00400).  In its memorandum, the OIG urges CMS to make Home Health Agency (“HHA”) intermediate sanctions a high priority and complete their implementation as soon as possible. Continue reading

New CMS Proposed Rule Concerning Reporting and Returning Overpayments

As part of CMS’ continued efforts to implement the provisions of the Patient Protection and Affordable Care Act, CMS proposed a new rule on February 16, 2012 (the “Proposed Rule”) that will require providers to report and return self-identified overpayments by the later of: (1) the date which is 60 days after the date when the incorrect payment was identified; or (2) the date any corresponding cost report is due, if applicable. Failure to report and return an overpayment within 60 days could result in a violation of the False Claims Act, civil monetary penalties, or exclusion from participation in Federal health care programs. Continue reading