HCCA: Updates from Dan Levinson at the OIG
I had the privilege of attending Dan Levinson’s talk this morning at the 18th annual HCCA conference. As the Inspector General, Dan has tremendous influence over hospital compliance. It was quite interesting to hear what’s on Dan’s mind and his goals for the OIG in 2014.
After mentioning the Halifax case several times, it was clear how Stark and AKB are still of great importance to the OIG and that they are pursuing cases actively. What’s particularly concerning about that case is the fact that the compliance officer repeatedly voiced her concerns over Stark violations was ignored by her executive team. Lesson learned: regardless of what impact addressing Stark violations might have on your organization, it will be better in the end to self-disclose and figure out a solution before facing a multi-million dollar settlement (in this case, $85 million).
The key areas for 2014 for the OIG, according to the IG, are:
- The new health exchanges (security, payments, etc.)
- Adverse events across all types of facilities, including the post acute setting
- New updates to the safe harbor laws (important for physician contracting!)
- New civil monetary penalties
- New exclusions