Leverage: Preventable readmissions and a recent OIG advisory opinion

Medicare's excess readmission penalty policy (up to a 1% ding in IPPS Medicare payments to hospitals that have excess readmissions for acute myocardial infarction, heart failure and pneumonia in FFY 2013, going up to 2% in 2014 — and adding in measures for hip and knee replacements and acute episodes of COPD patients — and […]

New OIG Self-Disclosure Protocol

The OIG released an updated self-disclosure protocol this week, about ten months after putting out a call for comments on the old protocol. The new protocol imposes some new burdens on the disclosing entity, such as a shorter timeline for internal investigations and reporting, and higher minimum fines. According to the OIG, the benefits of […]

Top Ten HHS Management and Performance Challenges

The OIG produces its list of Top Management and Performance Challenges (TMC) every year, and to no one's surprise, implementation of health reform tops the list this year.  The rest of the list includes a collection of fraud and abuse, quality of care and consumer protection priorities, plus a couple of interesting issues, such as […]

Health Care Compliance Association – Hot Tips from the US Attorney's Office at the New England Regional Conference

The Health Care Compliance Association's New England Regional Conference was held recently, and it was a day packed with useful information (and not just because I was one of the speakers).  I livetweeted the sessions (except my own), and I'd like to highlight the final session of the day, which featured Assistant U.S. Attorney Robert Trusiak, from […]

Accountable Care Organization (ACO) Regulations: First Look

ACO regulations and related federal issuances hit the street last Thursday, after several months of waiting — from CMS, OIG, FTC, DOJ and IRS.  They cover the waterfront, ranging from the central regulation defining the structure and workings of the ACO, to  limited Stark self-referral ban and anti-kickback statute waivers in the fraud and abuse […]

David Harlow quoted in AMA American Medical News story on daily deal websites

Groupon, LivingSocial and other daily deal websites are being used by health care providers — though thus far mostly by those that are not covered by traditional commercial or governmental health insurance (e.g., dental, chiropractic, acupuncture services).  Read the American Medical News story on Groupon, where I was quoted, and please take a look at […]