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When you are a pharmacist you are reponsible for administering drugs in a lawful and compliant manner. Logic tells you dispensing drugs to living persons is a starting point. However, one pharmacy recently found out what the repercussions were of administering drugs to "dead people." The owners of an independent pharmacy specializing in HIV and AIDS related medication agreed to pay the U.S. Government $7.8M to settle claims of overbilling CMS, which included dispensing medicine in the names of patients who have died. The settlement is to be paid in a duration of 5 years as the company makes money. A whistleblower brought the claim through aqui tam action alleging False Claims violations.
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The Office of Inspector General (OIG) developed a series of voluntary compliance program guidance documents directed at various segments of the healthcare industry to encourage the development and use of internal controls to monitor adherence to applicable statutes, regulations and compliance program requirement. The OIG compliance plan guidelines strive to assist in identifying and refining ongoing risk areas and compliance efforts. The OIG compliance program guidance documents range from hospitals and nursing homes to third-party billers and medical equipment suppliers. The following guidelines serve as a road map to existing compliance plans.
Ever try to build something without a plan or instructions? How did it turn out? Did you just “wing” it or go by a picture in your mind? That may work when you are building a kids’ skateboard ramp or even a dollhouse, but it’s not a good idea for running a compliance program in healthcare! How an organization develops and implements an effective compliance program – Good news, bad news: A compliance plan is just that – a plan. It will be viewed as a foundation from which to base decisions and actions taken by your organization. That’s the good news. On the flip side, it will also be used as a checklist and basis from which to hold an organization liable for following and adhering. That can be the bad news. This means that an “off-the shelf” plan that is copied or duplicated is not the best practice or means to the end.
Key takeaways from Inspector General Daniel R. Levinson’s Keynote Address at the 2016 HCCA Compliance Institute Levinson kicked off HCCA’s 20th year anniversary conference with a remarkable speech addressing the importance of compliance in healthcare. He emphasized how mature the compliance field has become and compared compliance to Nashville’s very own Athens of The South – the Parthenon. “This conference […]
ProviderTrust wishes you a Happy New Year! In celebration, we want to share with you what we've been up to this past year. From six new hires joining the team to multiple webinars to numerous Client Success cases solved to our greatest accomplishment of being awarded the NEXT Award, the ProviderTrust team remained busy in 2015.
We all know what doctors are and that they have to be licensed to practice medicine. But what is a POD and what do they have to do with doctors? POD — A POD stands for Physician Owned Distributorship. An example of a POD could be a medical device distributorship of hip replacements, heart pace makers or other devices. The distributorship is owned by a group of physicians and those physicians can order or determine which supplier/device is inserted or purchased for part of the medical treatment provided by the physician. Hence, the need to know if a hospital employed physician is an owner of a POD is critical in order to avoid possible STARK law violations and for transparency, according to the OIG. According to the OIG, it is not always clear which doctors have ownership interests in both PODS and the hospitals they sell the devices.
What happens if you are in default of your federal, or state, student loan (HEAL)? How prevelant is this issue? Defaulting on student loans is something you shouldn't overlook, especially if you are active in the healthcare industry. Let's look at who is excluded and placed on the exclusion list by the OIG for the exact reason mentioned above.
The term “know your vendor” gets thrown around in compliance and procurement circles. By the time your organization selects a potential third party for its expertise and reputation you have likely expended money, time and man-hours to vet your third parties. You should also allot time to collect key information about the company. But that is not all. You have one last set of steps to conduct before initiating the relationship with your vendor - examining the financial health of a vendor. Why is the financial health of your vendors important? One imperative component of effective vendor screening is to examine the financial health of the company. After all, it could put your company’s reputation, and even ability to service your client, in peril if the vendors you rely on are not able to deliver and/or have a history of defrauding or defaulting on their commitments.
Can you imagine a world where a single person provides all healthcare? No third-party contractors, suppliers, referring Physicians, reliance upon pharmaceutical companies, suppliers or manufactures? Sounds a little lonely and unlikely. Healthcare today requires a coordination of many people and organizations working in sync to provide quality and compliant care. No one person can provide all the care alone. Since hospitals, long term care companies, clinics, dialysis companies, dental practices and the like rely upon third-parties, suppliers and contractors to provide care and service, knowing who you are working and partnering with is paramount to quality and compliant care. Who are your Vendors/Contractors/Third Parties?
As a fast growing healthcare technology start up, ProviderTrust employees have to be willing to fill big shoes and adjust depending on need and change that occurs. This requires them to be highly motivated, confident self-starters. Not everyone is cut out for it. We're thankful to have a team full of employees that can do this and strive for excellence.
Since childhood, we learn to share and to never say "you can't play with us." Everyone loves to feel part of something or a group, and being excluded from a group or community can be pretty painful. As we get older, it does not get any easier. Now if the term "excluded" is tied to our professional career it takes on a whole new meaning - a very serious legal meaning. OIG Exclusions - In the healthcare industry, exclusions have a long-lasting and ulimately a punitive measure and are imposed by the Office of Inspector General of the HHS or a state Medicaid Exclusion authority that receives federal healthcare dollars. There are many OIG exclusions, also known as OIG sanctions, but the most common way for a healthcare professional to get excluded or sancitoned is due to a license revocation or termination for certain defined disciplinary matters. In most cases the state licensing board has a mandatory obilgation to exlcude or sanction a provider for a minimum of five years to a period up to indefinite for felony convictions that result from: Substance Abuse Patient Abuse Healthcare Fraud and Abuse However, there are permissive exclusion authority granted for misdemeanor convictions for the same and/or of defaulting on a federal student loan.