In what may prove to be the most substantial fraud and abuse rulemaking in over a decade, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) and Centers for Medicare & Medicaid Services (“CMS”) published on
Recently, the Office of Inspector General (OIG) published newly-issued guidance on the HHS OIG Grant Self-Disclosure Program (“Program”), which creates a formal framework for recipients, sub-recipients, and applicants for federal grant money to disclose potential violations of federal criminal, civil, or administrative law that may impact federally-awarded grants. Similar to the OIG’s Provider Self-Disclosure Protocol, the program offers incentives for self-disclosures in the form of reduced penalties and sanctions. The Program will be particularly important for individuals and entities, such as research universities, that receive federally-funded grants, as the Program establishes a specific process for making certain mandatory disclosures already required by law as well as provides guidance and incentives for making voluntary disclosures.
On December 7, 2016, the Office of Inspector General for the U.S. Department of Health and Human Services (“OIG”) issued a Policy Statement that increased the thresholds for gifts to Medicare and Medicaid beneficiaries to be considered “nominal” under the
On February 11, 2016, CMS issued a final rule clarifying the requirement of § 1128J(d) of the Social Security Act (created by § 6402(d) of the Affordable Care Act) that health care providers must report and return overpayments within 60