OIG Outlines Areas of Most Concern for Fraud and Abuse
Included in the model compliance plan was a list the Department of Health and Human Services' Office of the Inspector General (OIG) considers to be fraud and abuse risk areas in any health care organization. They were identified through previous investigations and audits, and the OIG says these areas now will be "areas of special concern."
The OIG also notes that "additional risk areas should be assessed as well by hospitals and incorporated into the written policies and procedures and training elements developed as part of their compliance programs." These are the specific areas highlighted by the OIG:
billing for items or services not rendered;
providing medically unnecessary services;
billing discharge in lieu of transfer;
patients' freedom of choice;
failure to refund credit balances;
hospital incentives that violate the anti-kickback statute or similar federal or state statute or regulations;
joint ventures;
financial arrangements between hospitals and hospital-based physicians;
Stark physician self-referral law;
knowing failure to provide covered services or necessary care to members of a health maintenance organization;
patient dumping.
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