What is a Board To Do?: Some Guidance from the OIG

By Matt Fisher – A practical guide for the governing boards of healthcare organizations was recently released through the joint effort of the Office of the Inspector General (“OIG”) of the Department of Health and Human Services, the American Health Lawyers Associated, the Association of Healthcare Internal Auditors and the Health Care Compliance Association.

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OIG Escalates Meaningful Use Audits of Hospitals

By Jim Tate – The Office of Inspector General (OIG) continues to aggressively audit eligible hospitals (EH) for their CMS EHR Incentive attestations. This week I received documents related to an audit recently initiated against a Medicaid EH. As far as the location goes, let’s just say it is west of the Mississippi River.

Ready for an OIG Security Audit?

By Elana Zana – At HIMSS15 in Chicago I had the pleasure of speaking with my colleague, Dave Schoolcraft, regarding the OIG Security Audits. These in depth security audits conducted not by the OCR or CMS, but rather the Office of Inspector General, delve into the security systems of Eligible Hospitals (and potentially Eligible Professionals) participating in the EHR Incentive Program.

Meaningful Use Audits 2.0

By Jim Tate – Most of us have gotten pretty used to the Meaningful Use (MU) audits being conducted by Figliozzi & Company. They are the folks that have been conducting the CMS EHR Incentive audits for both eligible hospitals (EH) and professionals (EP) involved in the Medicare or dually-eligible Medicare/Medicaid EHR incentive programs.

OIG Announces Multi-year Meaningful Use Audits Coming Soon

By Jim Tate – Lost in the furor and excitement of the recently released Proposed Stage 3 MU Rule something slipped by us. Robert Frost would say it “came on little cat feet”. John Lennon would say it came in “like a lizard on a window pane”. What is it that crept in through the cracks in the floor and why should we care?

Concerns for Preferred Provider Agreements

By Matt Fisher – Advisory Opinion 15-04 issued by the Office of the Inspector General (“OIG”) on March 25, 2015 offers some warnings when entering into preferred provider agreements. The new Advisory Opinion arose in the context of laboratory services, but the principles discussed are easily applicable to any preferred provider arrangement. The advice and insight are important in light of the increasing desire among providers to identify and enter into preferred provider agreements.

3 Steps: Drive Your Compliance Checkup Using the OIG Work Plan

By Robert Freedman – According to a report to Congress, that’s the amount returned to Uncle Sam in FY2014 as a result of healthcare oversight and investigations conducted by the Office of Inspector General (OIG). Avoiding this type of negative impact to cash flow and the bottom line is a matter of revenue integrity and is a high priority to most healthcare organizations.

Collections Allowed for Pre-Exclusion Services

By Matt Fisher – Advisory Opinion 15-02, issued by the Office of the Inspector General (“OIG”) for the Department of Health and Human Services on February 13, 2015 offers some, albeit minimal, relief for providers excluded from participation on Medicare and other federal healthcare programs.

More EHR Audits Planned for 2015

More EHR audits are on the way. The Office of the Inspector General (OIG) will continue to pay closer attention to the healthcare industry’s use of electronic health records–in particular HIPAA security, EHR incentive payments and fraud, according to the office’s recently released 2015 work plan.