Phase 2 HIPAA Audits Fast Approaching

In September 2015, HHS’ Office of Inspector General (OIG) issued a report encouraging HHS’ Office of Civil Rights (OCR) to strengthen its oversight of Covered Entities’ compliance with HIPAA privacy standards, and recommending that OCR fully implement a permanent...

The Continuing Government Assault on Physicians

On August 13, the Office of Inspector General for the Department of Health and Human Services (“OIG”) issued a “Memorandum Report” examining the overlap between physician-owned hospitals and physician-owned distributors (“POD”) of spinal devices. OEI-01-14-00270. The...

Medicare’s Improper Payment Outreach and Education Program

In April, the President signed into law the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which repealed and replaced the controversial Sustainable Growth Rate (SGR) formula.  A lesser known, but nevertheless important, provision of MACRA requires...

Fraud Liability For Meaningful Use Attestation

In December, Chilivis Grubman attorney Scott Grubman issued a healthcare compliance alert regarding the electronic health records (EHR) meaningful use incentive payment program.  That program, which began in 2009, provides financial incentives to providers who convert...