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Dec 01 2016

OIG's Work Plan Outlines 2017 Priorities

The United States Department of Health and Human Services ("HHS") Office of Inspector General ("OIG") released its Fiscal Year 2017 Work Plan ("2017 Plan") on November 10. OIG releases a work plan annually to identify the new and ongoing investigative, enforcement, and compliance activities that it will undertake during that fiscal year ("FY").

Takeaways from OIG's Work Plan
Healthcare organizations are well-advised to review their internal audit and compliance plans on a regular basis, and the 2017 Plan is a valuable resource in that effort insofar as the Plan outlines where OIG will focus its investigative resources. New initiatives indicate OIG's impending priorities, and audit and compliance continuing initiatives emphasize OIG's continued—and potentially heightened—interest in certain areas. OIG's stated priorities (including the degree of specificity of OIG's focus) can help an organization shape its compliance program for the coming year.

While the 2017 Plan covers a lot of territory, healthcare organizations should pay particular attention to those priorities involving hyperbaric oxygen therapy services, pharmaceutical and device pricing and reimbursement, and a renewed focus on post-acute care services.

OIG has noted that its work plan is an ongoing and evolving process, and the 2017 Plan may be updated throughout the year. The new administration will also likely have an effect on HHS and OIG priorities.

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Dec 07 2015

CMS Finalizes Two New Exceptions and Modifications to the Stark Law

The Centers for Medicare and Medicaid Services (CMS) recently published its final rule modifying several aspects of the federal physician self-referral law (the "Stark Law") and adding two new exceptions: one for recruitment of non-physicians providing primary care and the other for timeshare arrangements.

For the most part, CMS's changes lessen the Stark Law's compliance burden and aim for uniformity among the exceptions. At the same time, the two new exceptions create additional compliance and monitoring requirements for individuals and entities wishing to take advantage of the exceptions.

Most of the changes are effective January 1, 2016.

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