Category: Healthcare Compliance Programs

Getting Ready for Open Payments


Today, the Centers for Medicare and Medicaid Services (“CMS”) released additional tips regarding submitting Open Payments data.[1] A quick refresher: Submitting data through CMS’s application, Open Payments, is the means to fulfill the Sunshine Act, a federal regulatory requirement that applicable manufacturers, group purchasing organizations (“GPOs”), and health care providers disclose: a) certain transfers of...

DOJ Issues New, Practical Guidance on Effective Corporate Compliance Programs

Laura B. Morgan

On February 8th, the Department of Justice (DOJ) Criminal Division, Fraud Section issued new guidance (available here) on how it evaluates the effectiveness of a corporate compliance program when conducting an investigation of a corporation. This guidance is significant as it is the first of its kind since the confirmation of the new U.S. Attorney...

OIG Issues Practical Guidance for Health Care Governing Boards on Compliance Oversight

Benjamin Fee

April 24, 2015 On April 20, 2015, the Office of the Inspector General of the United States Department of Health and Human Services (“OIG”), in collaboration with the Association of Healthcare Internal Auditors, the American Health Lawyers Association and the Health Care Compliance Association, issued a new guidance document to assist governing boards of health...