the most recent ones, including the one issued October 16, 2015, reminds providers that if they are going to donate software or systems, such provider cannot engage in information blocking by not allowing such hardware/software to interact with other EHR systems or charging higher fees for interacting with other providers. Additionally, the June 9, 2015 document reiterated that physician compensation arrangements (in such instances medical directorships and office staff arrangements) which do not reflect fair market value constitute improper remuneration to physicians are subject to and Thus, for persons “criminal, civil, administrative sanctions.” intimately involved in fraud and abuse counseling regarding the recent issuances, there is typically rarely anything earth shattering in these fraud alerts but rather reinstatement of the existing safe harbors and other guidance, Set forth below is a list of the Fraud Alerts from June 25, 2014 Special Fraud Alert: Laboratory Payments to Referring Physicians. – March 26, 2013 Special Fraud Alert: Physician-Owned Entities. – January 1, 2013 Updated Special Fraud Alert: Telemarketing by Durable Medical – Equipment Suppliers. OIG Letter Regarding Updated Special Fraud Alert (03-02-2010): Telemarketing by Durable Medical Equipment Suppliers CMS Telemarketing Frequently Asked Questions March 3, 2003 Special Fraud Alert: Telemarketing by Durable Medical Equipment – Suppliers. February 23, 2003 Rental of Space in Physician Offices by Persons or Entities to Which – Physicians Refer.
the most recent ones, including the one issued October 16, 2015, reminds providers that if they are going to donate software or systems, such provider cannot engage in information blocking by not allowing such hardware/software to interact with other EHR systems or charging higher fees for interacting with other providers. Additionally, the June 9, 2015 document reiterated that physician compensation arrangements (in such instances medical directorships and office staff arrangements) which do not reflect fair market value constitute improper remuneration to physicians are subject to “criminal, civil, and administrative sanctions.” Thus, for persons intimately involved in fraud and abuse counseling regarding the recent issuances, there is typically rarely anything earth shattering in these fraud alerts but rather reinstatement of the existing safe harbors and other guidance, Set forth below is a list of the Fraud Alerts from June 25, 2014 – Special Fraud Alert: Laboratory Payments to Referring Physicians. March 26, 2013 – Special Fraud Alert: Physician-Owned Entities. January 1, 2013 – Updated Special Fraud Alert: Telemarketing by Durable Medical Equipment Suppliers. OIG Letter Regarding Updated Special Fraud Alert (03-02-2010): Telemarketing by Durable Medical Equipment Suppliers CMS Telemarketing Frequently Asked Questions March 3, 2003 – Special Fraud Alert: Telemarketing by Durable Medical Equipment Suppliers. February 23, 2003 – Rental of Space in Physician Offices by Persons or Entities to Which Physicians Refer.
FHL15_daniels.docx