OIG Advisory Opinion Recinded - Lessons Learned
December 21st, 2017 - Wyn Staheli
In the compliance world, it is important to know when the OIG makes an advisory opinion on a subject. For example, the advisory on Time of Service or Prompt Pay Discounts helps to ensure that providers are creating policies and procedures which will meet the standards of the OIG in the case of an audit.
Recently, the OIG rescinded advisory opinion 06-04 which concerned a nonprofit, tax-exempt, charitable corporation's proposal to provide financially needy Medicare beneficiaries with assistance with premiums and cost-sharing obligations. The original advisory was issued in 2006 and it was rescinded because:
We have made this determination based on Requestor’s failure to fully, completely, and accurately disclose all relevant and material facts to OIG.
If you are a nonprofit organization who provides benefits such as this and relied on this advisory, be sure to review the findings and make sure that your program's policies and procedures remain unaffected.
LESSONS LEARNED
1. For ALL types of providers, we want to take this opportunity to point out that the Requestor did not fully disclose information. When ANY governmental program makes a request for information, DO NOT file or throw it away and hope that nothing happens. It is best to carefully read the request and respond promptly and fully.
2. Compliance programs need to be monitored to ensure that they are still in compliance when rules and regulations change.
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