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

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.

The OIG’s FACES focus

IG Levinson took a significant portion of this presentation to discuss the OIG’s focus on certain fraud fighting tools through the acronym FACES –

  • False Claims
  • Anti-Kickback
  • Civil Penalties
  • Exclusions
  • Stark
As health care organizations develop compliance resources and continue to tweak compliance programs, the FACES acronym the OIG utilizes is a good tool for organizations to use in teaching the basics of the significant fraud and enforcement tools.

Compliance 101

IG Levinson also directed the audience to the OIG’s new Compliance 101 materials that can be found on its website at —> http://oig.hhs.gov/compliance/101/index.asp The site includes some very good materials on basic compliance issues and the OIG continues to add materials over time.

Excluded Person and Entities – Monthly Checks of the LEIE

The OIG has seen and continues to pursue significant enforcement efforts related to individuals who are excluded from federal health care benefit programs. These issues represent low hanging fruit for enforcement authorities. IG Levinson advised that his office is working on an update to their historical guidance on exclusions and expects to get that update out soon. One of the issues he raised about the update is that it will include an expectation that providers are checking exclusions lists on at least a monthly basis.  Providers often struggle to determine how often such checks should be done. IG Levinson remarked that the lists are updated monthly and providers should be checking them as they are updated.

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For more information on OIG enforcement priorities or regulatory enforcement in general, please feel free to contact Ari Markenson or any member of our health care practice group.

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