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Healthcare Compliance Risks with Urine Drug Testing Overpayments 

YouCompli

There has been significant enforcement over the last couple years relating to overpayments for UDT. Department of Health and Human Services Office of Inspector General (OIG) has expressed concerns about UDT billing. The overpayment rate for definitive drug testing for 22 or more drug classes was over 71%.

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New York State OMIG Makes Regulatory Modifications to Compliance Program Requirements

Health Law Advisor

In July 2022, the New York State Office of the Medicaid Inspector General (“OMIG”) proposed extensive modifications to the regulatory requirements governing compliance programs for entities receiving “significant” Medicaid revenue (increased by these regulations from a threshold of $500,000 to $1 million).

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OIG Issues Updated General Compliance Program Guidance: Overview of Key Elements & Changes

C&M Health Law

Compliance policies should be developed under the direction and supervision of the compliance officer and compliance committee and should address the implementation and operation of an entity’s compliance program and processes. OIG’s updated take on the seven elements is briefly summarized below. (1)

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Attention New York Medicaid Providers: It’s Time to Upgrade Your Compliance Program

Healthcare Law Blog

New Subpart 521-1: Compliance Programs The adopted regulations represent substantial changes to 18 N.Y.C.R.R. New Subpart 521-1: Compliance Programs The adopted regulations represent substantial changes to 18 N.Y.C.R.R.

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ChristianaCare Settlement Drives New Legal Theory in False Claims Act Litigation: Hospitals Take Note When Providing Clinical Services to Their Private Physician Groups

Healthcare Law Blog

million to resolve a lawsuit filed by the system’s former Chief Compliance Officer, Ronald Sherman. Sherman himself had submitted disclosure logs to the OIG), Sherman alleges that it failed to adequately report the arrangements it had with Neonatology Associates or any other private physician groups, or return any alleged overpayments.

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Compliance Risks Associated with Outlier Payments 

YouCompli

Compliance officers can help protect revenue and reduce the risk of penalties by collaborating with the Finance and Reimbursement departments to navigate the dynamics of outlier payments and prospective repayment. The government alleged these increased charges resulted in the greater number of outlier payments.

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Avoiding “Gotcha” Moments in Compliance 

YouCompli

As compliance officers, we are continually placed in a position to influence the actions of others and help shape our organization’s compliance culture. One way to change that perception is to avoid creating “gotcha” moments when you’re working on a compliance-related matter.