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Corporate Compliance Safeguards Against U.S. Department of Justice Prosecution: New 2020 Guidelines

Do You Have an Enterprise-Wide Culture of Compliance? In the Principles of Federal Prosecution of Business Organizations (“DOJ Principles”) the United States Department of Justice (DOJ) incorporates periodic guidance memoranda from the deputy attorneys general about how it should investigate and prosecute corporations. Set forth in the US Attorneys’ Manual, the DOJ Principles were updated…

A Quick Guide to Medicare Advance Beneficiary Notices (ABN)

As most providers are aware, procedures must be followed in detail for Medicare reimbursement, and an ABN is an integral part of those procedures. An Advance Beneficiary Notice of Noncoverage (ABN) is a waiver notice (standard government form CMS-R-131) that providers are required to give Medicare patients whose services may not be covered under Medicare….

Independence Day Reminds Us That Perseverance Pays Off

July 4, 2020 is yet another birthday for the United States, its 244th anniversary of the day the Declaration of Independence was signed. That was only the beginning of this great union. It took until September 17, 1787 to develop a written constitution and another year before it was ratified on June 21, 1788. But it…

How to Maintain FPPE and OPPE Compliance

FPPE and OPPE are Joint Commission standards for physician privileging. These processes, where a hospital evaluates the physician’s performance within a specific time frame, ensure quality of care and patient safety. Although hospitals determine their own criteria for performance monitoring and evaluation, failure to perform these processes could lead to Joint Commission citation. To help…

Common Healthcare Provider Credentialing Mistakes

Physician credentialing is the process in which a physician’s credentials are obtained, assessed, and verified. The proper credentialing steps can be complex and time-consuming but are a fundamental responsibility of hospitals and healthcare organizations. While it is often a tedious administrative task, poor execution can cause serious consequences. Credentialing mistakes lead to financial losses on…


Provider Credentialing with Good Documentation and Solid Bylaws Protects Against Litigation and Settlements. This blog outlines tips to avoid litigation around provider credentialing, privilege granting, and health care compliance. There is a great discrepancy between the facts of an event at the time of its occurrence and the memory of it weeks, months, or years…

Top Hospital Compliance Issues: HIPAA and Stark Law

HIPAA and Stark Law share several common characteristics. Both are a complex set of laws and regulations governing medical practice. Both constantly change as new regulations are added. Both require a high degree of effort to maintain compliance. Both also impose heavy penalties for violations, which have included multi-million dollar lawsuits for some. Hospitals should…

Vulnerabilities in Government Healthcare Programs

Medicare and Medicaid Management: A Guide to Protect Against Fraud In 1965, President Lyndon B. Johnson created the federally funded, health-related Medicare and Medicaid programs to aid vulnerable U.S. citizens. These programs are now the largest payers of inpatient hospital services, mental health services, long-term care services, and births. While both are federally funded, health-related…

The EPLS to Transition and What It Means for Healthcare Providers

What is the Excluded Parties List System (EPLS)? The Excluded Parties List System (EPLS) is a government database that lists people, vendors, and suppliers prohibited from receiving federal assistance, contracts, or subcontracts from the U.S. government. The EPLS is maintained by the General Services Administration (GSA), a federal agency. Healthcare entities who hire or contract…

What Is a Medical Sanction?

A medical sanction, also known as a healthcare sanction, is a disciplinary action levied against an individual or entity by a state licensing board. A sanction can severely damage an organization’s finances, operations, and reputation, and inhibit providers or entities from participating in federal healthcare programs. The U.S. Department of Health & Human Services (HHS)…