Publications

Hogan Lovells Publications

Department of Health and Human Services Office of Inspector General Proposes New Anti-Kickback Safe Harbors and Exceptions to Civil Monetary Penalties Statute

On 1 October 2014 the Department of Health and Human Services Office of Inspector General published a proposed rule that would create three new federal anti-kickback law (AKL)...

Hogan Lovells Publications

OIG Report and Special Advisory Bulletin Identify Vulnerabilities in Copay Coupon Processing

On 19 September 2014 the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) released a report reviewing the effectiveness of safeguards that...

Hogan Lovells Publications

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...

Hogan Lovells Publications

HHS: Qualified Health Plans Are Not 'Federal Health Care Programs'

In a letter to Rep. Jim McDermott, Health and Human Services (HHS) Secretary Kathleen Sebelius answered a question frequently asked by healthcare providers and pharmaceutical and device...

Hogan Lovells Publications

OIG approves tiered rebate program based on combination of purchases

The Office of Inspector General for the Department of Health and Human Services (OIG) released a new Advisory Opinion on July 1 (OIG Advisory Op. 13-07) approving a proposed arrangement by...

Hogan Lovells Publications

HHS-OIG updates Special Advisory Bulletin on effect of exclusion from federal healthcare programs

On May 8, 2013, the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) published an updated Special Advisory Bulletin (SAB) on the scope and effect of...

Hogan Lovells Publications

OIG releases revised and expanded self-disclosure protocol

On April 17, 2013, the Office of Inspector General of the Department of Health and Human Services (OIG) released a revised self-disclosure protocol (SDP) that significantly overhauls the...

Hogan Lovells Publications

CMS provides opportunity to comment on certain elements of Sunshine regulations

In follow-up to the release of the final regulations implementing the federal Physician Payment Sunshine (Sunshine) provisions, the Centers for Medicare & Medicaid Services (CMS) has...

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