If you’re like me and track email updates from the Office of Inspector General – better known as the OIG – then you probably know about the weekly financial settlements many health care organizations face. But now that the new year is upon us, what can we expect from the OIG in 2019 – specifically, as it relates to physician-hospital arrangements? From my perspective, the OIG’s 2019 work plan is consistent with what we have seen the past few years. In September, the OIG released their latest semiannual report to Congress, summarizing the prior six months. If you’re not familiar with this report, the OIG partners with the Department of Justice (DOJ), State Medicaid Fraud Control Units and other Federal, State and local law enforcement agencies to fight fraud in Health and Human Service (HHS) programs. It can be tough to sort through, but it’s helpful to understand some of the report’s implications, especially if you’re part of a hospital or health system.
Personally, I was taken back by the number of financial recoveries in 2018 that also had a criminal settlement. In fiscal year 2018, the OIG reported recoveries of $2.91 B, criminal actions against 764 individuals and entities, and civil actions against 813 individuals and entities. But it’s not all bad news in the world of the OIG. In fact, if you’re willing to put in the time, their semiannual report is full of useful information that, collectively, can act as your proverbial north star in the regulatory landscape.
I’ve outlined three implications from the recent OIG report that specifically relate to physician-hospital arrangements.
1. US Department of Health and Human Services, OIG, Semiannual Report to Congress April 1, 2018-September 30, 2018.
2. OIG, Active work plan items, oig.hhs.gov.
3. Yates memo, September 9, 2015 and can be downloaded at https://www.justice.gov/archives/dag/file/769036/download.