Thursday, September 18, 2014
OIG has published an on-line pamphlet called “A Roadmap for New Physicians, Avoiding Medicare and Medicaid Fraud and Abuse.” http://oig.hhs.gov/compliance/physician-education/roadmap_web_version.pdf. In it, the OIG provides physicians with an overview of the five primary health care fraud and abuse laws: (1) False Claims Act; (2) Anti-Kickback Statute; (3) Physician Self-Referral (“Stark”) Law; (4) Exclusion Statute; and (5) Civil Monetary Penalties Law. The aim of the pamphlet is to help physicians avoid running afoul of the law in connection with their relationships with (1) Payers, such as Medicare and Medicaid; (2) Fellow Providers, including physicians, hospitals, nursing homes and other providers; and (3) Vendors, including the Pharmaceutical and Medical Device Industries. The pamphlet is only 31 pages in length and provides the reader with examples of what conduct not to engage in and, equally importantly, the mindset of OIG as it continues to ramp up its investigations of health care fraud allegations.