Supplemental Compliance Guidance for Hospitals Issued

By Susan F. Koch

 

On January 27, 2005, the Office of Inspector General of the Department of Health and Human Services (OIG) issued the final version of supplemental compliance guidance for hospitals.   This issuance supplements the original compliance guidance for hospitals released by the OIG in 1998, and provides expanded discussions about fraud and abuse risk areas, including (1) the submission of accurate claims and information, (2) the referral statutes, (3) payments to reduce or limit services, (4) EMTALA, (5) substandard care, (6) relationships with federal health care beneficiaries, (7) HIPAA privacy and security rules, and (8) billing Medicare or Medicaid substantially in excess of usual charges, as well as a discussion to evaluate the effectiveness of compliance programs.   Much of the document's content remains unchanged from the draft guidance issued on June 8, 2004, although there are substantial changes to the section pertaining to compensation arrangements with hospital-based physicians.   The issuance does not create any new law or legal obligations, but is intended to be used as a starting point for a hospital's legal review of its operations, and for the development or refinement of policies and procedures to reduce potential risk.   The Supplemental Compliance Guidance is expected to be printed in the Federal Register on January 31, 2005, but can be obtained immediately on the Inspector General's website.  Click here to view the Inspector General's website.

 

If you have any questions concerning the supplemental compliance guidance, please contact Susan Koch at (713) 752-4328.

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