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 […]

OIG review finds about 1/3 of all Medicare nursing home stays had inadequate care, care planning or discharge planning

As part of the US Department of Health and Human Services Office of Inspector General's current focus on nursing facilities, the OIG recently released a report entitled: Skilled Nursing Facilities Often Fail To Meet Care Planning and Discharge Planning Requirements. From the OIG summary: Skilled nursing facilities (SNF) are required to develop a care plan for […]

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 […]

Accountable care organization proposed regulations released for public comment

The long-awaited ACO regulations were released by CMS in draft form today, accompanied by a series of conference calls for different constituencies.  Here is a mirrored copy: Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations – Proposed rule. CMS Administrator Don Berwick introduced the regulations as implementing a vision of spreading the benefits of […]