OIG Guidance and Reports

Nolan & Auerbach, P.A’s Healthcare-fraud whistleblower attorneys provide experienced representation under the qui tam provisions of the False Claim Act. Our qui tam attorneys file Medicare fraud and other Healthcare fraud qui tam lawsuits for our clients, drawing on a wealth of experience and resources. The following are some OIG Compliance Guidances, and Reports on areas related to Healthcare fraud, Medicare fraud, Pharmaceutical fraud, DSH fraud and other areas that our qui tam attorneys focus on:

Office of Inspector General’s Compliance Program Guidance for Nursing Facilities
This Compliance Program Guidance for Nursing Facilities was developed by the Office of Inspector General (OIG). The OIG has previously developed and published compliance program guidance focused on several other areas and aspects of the health care industry. The development and issuance of this compliance program guidance for nursing facilities was intended to serve as a positive step toward reducing violations of the false claim act and promoting a higher level of ethical and lawful conduct throughout the entire health care industry.

OIG Compliance Program Guidance for Ambulance Suppliers
This Compliance Program Guidance for Ambulance Suppliers was developed by the Office of Inspector General (OIG). The OIG has previously developed and published voluntary compliance program guidance focused on several different areas of the health care industry. This voluntary compliance program guidance was intended to assist ambulance suppliers and other health care providers in developing their own strategies for complying with federal health care program requirements and preventing false claim act violations.

OIG Compliance Program Guidance for Pharmaceutical Manufacturers
This Federal Register notice sets forth the Compliance Program Guidance for Pharmaceutical Manufacturers was developed by the Office of Inspector General (OIG). Through this notice, the OIG is setting forth its general views on the value and fundamental principles of compliance programs for pharmaceutical manufacturers and the specific elements that pharmaceutical manufacturers should consider when developing and implementing an effective compliance program. The guidance overviews most areas of Pharmaceutical fraud.

Medicare Payments For Enteral Nutrition
This inspection compared the amount Medicare reimburses for Category I enteral nutrition formulas (procedure code B4150) to prices available to the supplier community. Medicare fraud enforcement would be welcome in this area.

St. Vincent Charity Hospital & St. Luke’s Medical Center DSH Review
The objective of the review was to confirm that disproportionate share hospital (DSH) payments to St. Vincent Charity Hospital and St. Luke’s Medical Center (collectively, the Provider) during Federal fiscal year 2000 did not exceed the DSH payment limits imposed by the Omnibus Budget Reconciliation Act of 1993. DSH fraud is still alive and well, and should be considered a major enforcement objective in the future.

Medicaid Rebates For Physician-Administered Drugs
This OIG Report had 2 Objectives:
(1) To determine whether all State Medicaid agencies collect drug manufacturer rebates for all physician-administered drugs; (2) To estimate the potential savings that would result if all State Medicaid agencies collected drug manufacturer rebates for physician-administered drugs. The discovery of Medicaid rebate fraud is gaining ground, although this particular problem seems to have resolved due to clearer regulations.