When Daniel Levinson, the Department of Health and Human Services Inspector General (IG), took the stage at the recent Healthcare Compliance Association (HCCA) conference in “our nation’s capital,” he compared the current healthcare environment to a maritime voyage.
After his kickoff speech, he joined RACmonitor’s on-site broadcast and explained his analogy this way:
“We’re really on a voyage these days, heading toward more effective and more efficient healthcare. Because this is going to require some new navigation skills, I thought emphasizing the maritime nature of our voyage, rather than a voyage on land where landmarks are more obvious, would be a good metaphor to underscore where we are trying to head, some of the challenges we face, and the importance of new technologies that will help us navigate more effectively.”
Levinson emphasized the important role that the compliance community plays in this voyage—one of effective partners who are “vital” to the Office of Inspector General’s (OIG) ability to ensure hospitals, physician groups, and others manage effectively. He called his office “modest” in terms of size and resources, which is why they depend upon the compliance community. Compliance officers and their staff “extend the reach so that together we can ensure that providers can function effectively and cooperatively in accordance with our rules,” he explained.
Another partner that the IG’s office has embraced is social media, which he views as remarkable and revolutionary for communicating the messages it needs to send to the industry. He credited OIG technical experts for extending the office’s reach to Facebook, Twitter, and You Tube. Levinson indicated that they have collected all of their communications on their website at https://oig.hhs.gov/.
Check OIG Website for Key Issues
In the wrap-up of his RACmonitor interview, Levinson encouraged healthcare providers to visit the OIG’s website, especially because it now includes several vital issues. Specifically:
- Updated self-disclosure protocol—a new document issued recently that, Levinson says, “will help providers help themselves to be able to identify, disclose and resolve fraudulent conduct that might have occurred.” (Direct link: https://oig.hhs.gov/compliance/self-disclosure-info/files/Provider-Self-Disclosure-Protocol.pdf)
- Special fraud alert—a recently issued document about physician-owned distributorships (PODs), which are “inherently suspect because of the potential anti-kickback liability that may occur whether one is in a hospital or ASC” (ambulatory surgical center). (Direct link: https://oig.hhs.gov/fraud/docs/alertsandbulletins/2013/POD_Special_Fraud_Alert.pdf)
- Safe harbor notice—another recently issued document that extends and updates the current safe harbor, which expires related to the donation of electronic health record (EHR) equipment and whether and how the OIG should extend the protection to, as Levinson notes, “ensure and promote the interoperability of EHR.” (Direct link: https://oig.hhs.gov/authorities/docs/2013/EHR_Safe_Harbor_Proposed_Rule.pdf)
To review all of the above and more, in addition to submitting comments as requested, go to the above links or https://oig.hhs.gov/.
And don’t worry whether you’ll be able to understand this legalese because, the IG promises that it is “readily available and provided in a way that layman and attorney can understand what is at stake.”
About the Author
Janis Oppelt is editor for MedLearn Publishing, a division of Panacea Healthcare Solutions, Inc., St. Paul, Minn.
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