The Centers for Medicare and Medicaid Services, Office of the Inspector General (“OIG”) published a Proposed Rule in the September 20, 2016 Federal Register that would change the structure and expand the authority of State Medicaid Fraud Control Units (“MFCU”). The OIG wants to change the Federal participation in the costs attributable to establishing and
OIG Issues New Fraud Alert on Physician Compensation Arrangements Such As Medical Director Agreements
On June 9, 2015, the OIG issued a new Fraud Alert, cautioning physicians who enter into compensation arrangements such as medical directorships to ensure that the arrangements reflect fair market value for bona fide services that the physicians actually provide. The OIG reiterated that a compensation arrangement could violate the Anti-kickback Statute if even one
OIG Would Not Sanction Arrangement Involving Payment to Excluded Provider for Pre-Exclusion Services
The latest OIG Advisory Opinion, issued February 9, 2015, addresses the issue of sharing federal health care program payments with an excluded practitioner. While federal statutes prohibit payment by any federal health care program, including Medicare or Medicaid, for items or services furnished by an excluded person or furnished at the medical direction or on