CHA News Article

New OIG Litigation Team to Focus on Penalties

The Office of Inspector General (OIG) at the U.S. Department of Health and Human Services on June 28 announced it is creating a litigation team focused on assessing civil monetary penalties against providers and suppliers who do not comply with Medicare and Medicaid fraud and abuse-related rules. These providers and suppliers may also be excluded from participation in the federal health care programs. OIG is hiring additional lawyers to increase enforcement; the team will target overbilling as well as kickbacks that may inappropriately influence medical judgment. OIG expects to bring more cases against both the payors of the kickbacks as well as the recipients. Hospitals may wish to review their physician arrangements and contracting policies to help ensure compliance with the anti-kickback and physician self-referral laws.

CHA publishes the California Hospital Compliance Manual, written by Hooper, Lundy & Bookman, PC, which focuses on high-risk compliance issues and key components of an effective compliance program. The manual contains extensive discussion of the federal anti-kickback, physician self-referral and civil monetary penalties laws, as well as related state laws.

The 2015 edition also explains changes to state law regarding new hospital financial assistance policies and federal requirements of new IRS regulations released on Dec.31, 2014. A model compliance plan that hospitals can adapt to fit their operations is available on the free CD, along with the Hospital Signage Requirements chart, posters and appendixes. The manual also includes legal citations and an index of key terms. For additional details on the Compliance Manual or to order a copy, visit