Healthicity Blog

Though many CIAs read very similarly, it’s good practice to read new ones to reaffirm some of the core principles of an effective compliance program.

“Any company or individual receiving anything of value in exchange for referrals should understand that their actions may have serious legal and financial consequences.”

Those of you who have been following my work on the Healthicity blog, my webinars and/or speaking engagements know that one of my topics of choice is the government's increased efforts to hold individuals, not just organizations, accountable for suspected non-compliance.

Most of us have seen the emotionally charged video of University of Utah nurse, Alex Wubbels, being arrested by Salt Lake City Police after refusing to allow the police to draw blood from an unconscious patient.

The OIG has updated their work plan in the last year more frequently than in the past and recently added nine more items in September of 2017. Anytime the OIG updates their work plan, I think it’s important to take a deep dive into the new content.

When a lot of healthcare organizations consider their risk under the False Claims Act, they often think of coding and billing errors submitted on 1500s or UBs. It’s probably the first place I’d consider looking as well for the greatest risk to a Medicare or Medicaid healthcare provider.

If you have a compliance program, you most likely have a full-time compliance officer or an individual who is accountable for your organization’s compliance program, even if it’s only a portion of that person’s overall duties.

Many compliance programs rely on the OIG Work Plan when planning their own internal audit or compliance activities. Historically, the OIG Work Plan was updated annually. However, recently the OIG has been publishing periodic updates and additions more often.