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OIG Newly Updated Exclusion Criteria as of April 18, 2016

On April 18, the OIG updated the criteria it uses to determine whether exclusion or a lesser penalty is the appropriate remedy – underscoring the renewed emphasis the OIG is placing on this important weapon in its arsenal to fight against fraud and abuse.   

The Office of Inspector General (OIG) has the authority to exclude individuals or entities (collectively “person”) that engage in illegal or fraudulent conduct from participation in Federal health care programs to protect the...

CMS Passes 60-Day Overpayment Final Rule

On February 12, 2016, the Centers for Medicare and Medicaid Services (CMS) published a Final Rule that provides guidelines to Medicare providers about their duty to report and return overpayments.  These new regulations define what it means to “identify” an overpayment and provide detailed guidance regarding Medicare providers’ overpayment obligations. 
 

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CMS Finalizes New Fraud Safeguards Including Ambulance Backbilling

#000000;">The Centers for Medicare & Medicaid Services (CMS) just issued a #0000CD;">Final Rule#000000;"> intended to improve CMS’s ability to deny or revoke the enrollment of entities and individuals that pose an integrity risk to the Medicare program.  This Rule would also significantly limit ambulance suppliers' ability to...

OIG Proposes Safe Harbor for Cost-Sharing Waivers for Emergency Ambulance Services

On October 3, 2014 the Office of the Inspector General is set to publish a Proposed Rule that would establish a new safe harbor under the Anti-Kickback Statute (AKS) that would permit waivers of cost-sharing amounts for emergency ambulance services furnished by State or municipally-owned ambulance providers and suppliers.  But, there are conditions that must be met in...

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Proposed Rule to Increase Fraud and Abuse Penalties

On May 12, 2014, the Department of Health and Human Services (HHS) issued a Proposed Rule that would significantly enhance the Office of the Inspector General’s (OIG) authority to impose civil money penalties (CMPs).  The OIG has the ability to impose CMPs on providers who participate in Federal health care programs for various activities related to health care fraud, patient abuse, and...

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8 Big Findings From the OIG’s Utilization Report

September 25, 2013, the Department of Health and Human Services Office of Inspector General (OIG) released a Report, Utilization of Medicare Ambulance Transports, 2002-2011, that takes a critical look at the growth of Part B Medicare ambulance transports since 2002.  The Report finds that since...

New OIG Advisory Opinion Allows No Bills for Municipal Residents, But Bills for Non-Residents

On July 9, 2013 the OIG posted Advisory Opinion 13-08, concerning a Fire Protection District ("District") policy of only billing individuals that reside outside the fire protection district for emergency medical services. Here, the District does not bill any residents or their insurers (including federal health care programs) for emergency medical services. But it does bill all...

OIG Issues Updated Special Advisory Bulletin on Excluded Individuals

Background
 
On May 8, 2013, the Office of the Inspector (OIG) issued an updated “Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs.”  Ambulance providers enrolled in Federal healthcare programs may not employ or contract with any party who is excluded from...

OIG Report on Claims with G Modifiers

On May 3, 2013 the OIG issued: Medicare Payments for Part B Claims with G Modifiers, assessing how Medicare contractors are processing G modifiers.  The OIG analyzed all Part B claims with GA, GZ, GX, or GY modifiers from 2011 and found that there were “vulnerabilities in how Medicare pays for these claims” resulting in improper payments of claims submitted with G...