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About October each year, the Office of Inspector General (OIG) within the Department of Health and Human Services issues its annual Work Plan for the coming year. The plan describes the activities that OIG will focus on to protect the integrity of the federal health care programs. In general, a review of relevant sections of […]

“So what happened in health care this summer?” the recently vacationing physician asked his rather jumpy health care lawyer. “I think the question is what didn’t happen?” the lawyer responded. The summer was fairly busy in the health care legal arena. Some things happened, some were pushed off, and some may be pushed off for […]

On May 20, 2009, President Obama signed the Fraud Enforcement and Recovery Act (FERA) into law. The main policy reason behind FERA was to address fraud in the mortgage industry. The law, however, broadly expands the scope of the federal False Claims Act which is the primary tool used by the government to prosecute fraud […]

on april 30, 2009, the federal trade commission (ftc) announced it will delay enforcement of the red flags rule from may 1, 2009 until august 1, 2009. given the eleventh-hour notice, health care providers can breathe a sigh of relief for now. there is some indication that congress may narrow the scope of the law, […]

on may 1, 2009, health care providers who are considered creditors should begin compliance efforts with the federal trade commission’s (ftc’s) red flags rule aimed at identity theft protection. the application of the red flags rule to some health care providers such as physicians continues to be a point of controversy, and organizations like the […]

on march 24, 2009, the office of inspector general (oig) for the department of health and human services issued an open letter about its voluntary self-disclosure protocol. in the past, oig encouraged use of the protocol to self-report suspected violations of law related to the federal health care programs. in 2006, oig specifically invited disclosures […]