Author Description

The 2014 Supplement notes the following issues in one or more chapters: The increasing number, scope, and scale of fraud and abuse enforcement actions at the federal and state levels, including: a kickback/off-label promotion settlement exceeding $2 billion; Strike Force initiatives; the 2014 OIG Work Plan; the moratorium on home health agency and ambulance supplier enrollment in certain high risk areas; and notable defense victories Numerous new sets of rules including the OIG s proposed regulations related to their civil monetary penalty and exclusion authorities Developments related to the statutory requirement to return overpayments within 60 days of identification and the varying proposed regulations that have been issued to implement it New OIG guidance, including a new Special Fraud Alert and the termination of a previously issued advisory opinion Numerous Part D-related developments including False Claims Act cases and settlements, recent CMS enforcement actions, OIG studies on fraud and abuse related to Part D, and the CMS overutilization monitoring system RAC program amendments and the two-year suspension of appeals