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HHS-OIG Proposes Significant Amendments to Exclusion and Civil Monetary Penalties Regulations

In the span of three days, the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) published two proposed rules in the Federal Register that substantially ...

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OIG Issues Supplemental Special Advisory Bulletin Expanding Guidance on Independent Charity Patient Assistance Programs

Likely in response to recent controversy and public scrutiny, on 21 May 2014, the Office of Inspector General issued a supplemental Special Advisory Bulletin regarding independent...

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POD Promoter “Spin” Notwithstanding, OIG’s Special Fraud Alert on PODs Puts Current POD-Hospital/ASC/Manufacturer Relationships at Risk

As noted in our recent post, OIG’s recent Special Fraud Alert on Physician-Owned Entities is the strongest statement to date that investing in or doing business with a physician-owned...

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Protecting EHR Donations 2.0

In today’s Federal Register, OIG and CMS propose three discrete revisions to existing regulations protecting the donation of electronic health records and solicit comments for potentially...

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OIG: PODs “inherently suspect” under anti-kickback statute; Hospitals and ASCs warned of AKS risks to them if they purchase from PODs

In its strongest statement so far on the subject, the HHS Office of Inspector General (OIG) today released a Special Fraud Alert which concludes that physician-owned entities that...

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Sunshine Regulations to Unmask PODs' Financial Relationships

The final Sunshine regulations, published in the Federal Register on February 8, require applicable manufacturers (“AMs”) and applicable GPOs (“AGPOs”) to submit reports on physician...

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