Office of Inspector General

On November 6, 2023, the Office of Inspector General (“OIG”) issued its long-awaited General Compliance Program Guidance (“Guidance”) “to help advance the industry’s voluntary compliance efforts in preventing fraud, waste, and abuse in the health care system.” Although the Guidance is nonbinding, it reflects the OIG’s expectation that compliance programs become increasingly sophisticated in their approach to identifying and managing compliance risks as healthcare delivery and payment models continue to evolve.

The Department of Health and Human Services (HHS) through its Office of Inspector General (OIG), announced plans for significant updates and modernization of OIG compliance program guidance (CPG) to improve their accessibility and usability for healthcare entities.[1] Originally issued in 1998, the CPG provide healthcare organizations across the industry with guidance on developing, implementing, and maintaining internal compliance controls. In the 25 years since, the OIG has issued multiple and specific CPGs that apply to particular segments of the healthcare industry including Medicare Advantage organizations, hospitals, home health agencies, nursing homes, and clinical laboratories. However, over time the CPGs have not sufficiently kept up with the innovations and growth of the healthcare industry.

Hospice Insights

As many hospices continue to diversify into new business lines, staying abreast of enforcement trends outside of hospice is more important than ever. Home health in particular, is receiving significant government scrutiny. In this episode, Husch Blackwell’s Meg Pekarske talks with Bryan Nowicki and Erin Burns about a new round of home health audits being…

Hospice Insights

The Office of Inspector General (OIG) recently announced that its 2022 work plan for hospices will include a nationwide review of hospice beneficiary eligibility. In this episode, Husch Blackwell’s Meg Pekarske and Bryan Nowicki discuss what led to this latest effort by the OIG, what hospices can expect and what they should do. Listen today:…

An Attorney’s Perspectives for Hospice Boards

Hospice boards today need to be well-versed in a number of areas that directly or indirectly address legal issues. In this three-part Hospice Governance Academy Spotlight Interview, Bill Musick, President of Integriti3D, talks with Meg Pekarske, a partner at Husch Blackwell and host of the podcast, “…

COVID-19 is not the sole focus of the Department of Health and Human Services (“HHS”) these days. On May 15th, the Office of Inspector General (“OIG”) announced that it added to its Work Plan a “Review of Institutions of Higher Education Grantees Receiving National Institutes of Health Awards” to address areas of potential risk at institutions of higher education (“IHE”).

Representatives of the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) are reaching out to speak with hundreds of hospital officials nationwide to provide feedback to HHS and to Congress about the most difficult challenges that hospitals are currently facing in responding to COVID-19.  The OIG emphasizes that…