The US Department of Health and Human Services Office of the Inspector General (HHS OIG) recently unveiled a new toolkit that seeks to help analyze telehealth claims for federal healthcare program integrity risks. It is based on methodologies highlighted in OIG’s September 2022 data brief; the data brief identified billing practices by Medicare providers that OIG was concerned posed a high risk to program integrity. OIG intends for the toolkit to be used by public and private parties—including Medicare Advantage plan sponsors, private health plans, State Medicaid Fraud Control Units and other federal healthcare agencies—to assess program integrity risks and identify providers whose billing may warrant further scrutiny.
HHS OIG Develops Toolkit to Analyze Telehealth Claims to Assess Program Integrity Risks
By James A. Cannatti III, Amanda Enyeart, Marshall E. Jackson, Jr., Tony Maida, Lisa Schmitz Mazur and Dexter Golinghorst on June 13, 2023
Posted In Employee Benefits, Health and Welfare Plans

James A. Cannatti III practices at the intersection of today’s most pertinent healthcare issues, including in the areas of digital health, health IT policy, and the fraud and abuse laws. He counsels healthcare providers, health information technology companies, and other healthcare and life sciences organizations on matters ranging from Anti-Kickback Statute, Stark Law and EKRA compliance to information blocking and interoperability. With more than a decade spent in the Office of Inspector General (OIG) at the US Department of Health and Human Services, and the wealth of experience gained from serving as OIG’s Senior Counselor for Health Information Technology, James is well-attuned to the regulatory issues impacting the rapidly evolving healthcare landscape. Read James A. Cannatti III's full bio.

Amanda Enyeart maintains a general health industry and regulatory practice, focusing on fraud and abuse, information technology and digital health matters. Amanda advises health care industry clients in all aspects of software licenses and other agreements for the acquisition electronic health record (EHR) systems and other mission critical health IT. Amanda’s health care IT transactional experience also includes advising clients with respect to software development, maintenance, service and outsourced hosting arrangements, including cloud-computing transactions. Read Amanda Enyeart's full bio.

Marshall E. Jackson, Jr. focuses his practice on transactional and regulatory counseling for clients in the health care industry, as well as advises clients on the legal, regulatory and compliance aspects of digital health. Marshall provides counseling and advice to hospitals and health systems, private equity firms and their portfolio companies, post/sub-acute providers, physician practices, and other public and private health care companies in a variety of complex transactions and health regulatory compliance matters. Read Marshall Jackson's full bio.

Tony Maida counsels health care and life sciences clients on government investigations, regulatory compliance and compliance program development. Having served as a government official, Tony has extensive experience in health care fraud and abuse and compliance issues, including the federal and state Anti-Kickback and Stark Laws and Medicare and Medicaid coverage and payment rules. He represents clients in False Claims Act (FCA) qui tam matters, government audits, civil monetary penalty and exclusion investigations, and Centers for Medicare and Medicaid Services (CMS) suspension, and revocation actions, negotiating and implementing corporate integrity agreements, and making government self-disclosures. Read Tony Maida's full bio.

Lisa Schmitz Mazur advises health care providers and technology companies on a variety of legal, regulatory and compliance matters with a particular focus on digital health topics, including telehealth, telemedicine, mobile health and consumer wellness. Lisa advises a variety of health care providers and technology companies involved in “digital health,” including assisting clients in developing and implementing telemedicine programs by advising on issues related to professional licensure, scope of practice, informed consent, prescribing and reimbursement. Lisa helps clients identify and understand the relevant legal issues, and develop and implement practical, forward-thinking solutions and strategies that meet the complex and still-evolving digital health regulatory landscape. Read Lisa Schmitz Mazur's full bio.

Dexter Golinghorst focuses his practice on health law matters, providing regulatory and operational advice to traditional healthcare providers, industry innovators and other healthcare and life sciences clients. Dexter also assists in transactional matters, performing due diligence, drafting and reviewing agreements and providing counsel on compliance matters for mergers, acquisitions, joint ventures and other strategic transactions. Read Dexter Golinghorst's full bio.
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