Tag Archives: AKS

Loan or Other Financial Obligation Forgiveness– A Continuing Fraud and Abuse Challenge

There are many health care financial arrangements where one entity has a financial obligation to another, with whom it either does business directly, or to which it makes referrals, and that obligation is either past due or for one reason or another cannot be paid. This may come up, for example, in the context of … Continue reading this entry

What to Know About new HHS Civil Monetary Penalties

Preparing for the Conversion to ICD-10
More than two years after first proposing regulations, the Office of Inspector General of the U.S. Department of Health and Human Services issued two final rules updating its (1) civil monetary penalty (CMP) regulations, 81 Fed. Reg. 88,334 (Dec. 7, 2016), and (2) safe harbors under the anti-kickback statute (AKS) and beneficiary inducement prohibitions, 81 … Continue reading this entry