The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) is tasked with providing objective oversight to protect the integrity and promote the efficiency of Medicare, Medicaid, and more than 100 other federal healthcare programs, as well as the health and welfare of the people they serve.

Bass, Berry & Sims is pleased to share its second annual HHS-OIG Year in Review, a novel industry resource highlighting key OIG guidance issued in 2023, including:

  • The new General Compliance Program Guidance.
  • The expanded informal FAQ process.
  • The new civil monetary penalties for information blocking.
  • OIG’s strategic plan for managed care oversight.
  • A consumer alert regarding remote patient monitoring.
  • The end of the public health emergency declaration.
  • OIG’s new telehealth toolkit.
  • Significant advisory opinions.
  • Significant SDP settlements.
  • Litigation against OIG challenging unfavorable advisory opinions.

We hope that this tool will assist you in understanding how OIG frames and analyzes fraud and abuse issues so that you can assess and manage risk as you navigate the ever dynamic healthcare regulatory environment.

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Photo of Kristin Bohl Kristin Bohl

Kristin Bohl blends her experience as a healthcare attorney in private practice and government service with first-hand knowledge of care delivery as a registered nurse. Kristin advises hospitals, health systems and other provider organizations on compliance and regulatory issues and fraud and abuse…

Kristin Bohl blends her experience as a healthcare attorney in private practice and government service with first-hand knowledge of care delivery as a registered nurse. Kristin advises hospitals, health systems and other provider organizations on compliance and regulatory issues and fraud and abuse matters, with a focus on the wide range of Medicare payment models. Before she entered private practice, Kristin was the Technical Advisor in the Division of Technical Payment Policy at the Centers for Medicare & Medicaid Services (CMS), where she concentrated on Stark Law matters. She was part of a team that developed the CMS Voluntary Self-Referral Disclosure Protocol and provided technical assistance in the creation of Stark Law waivers for Accountable Care Organization (ACO) models and other payment initiatives of the Center for Medicare and Medicaid Innovation within CMS.

Photo of Justin Brown Justin Brown

Justin Brown focuses on healthcare fraud and abuse matters, particularly those involving the federal physician self-referral law (Stark Law), the federal Anti-Kickback Statute, and state analogs. He represents hospitals and health systems, ambulatory surgery centers, post-acute care providers, and physician practices, along with…

Justin Brown focuses on healthcare fraud and abuse matters, particularly those involving the federal physician self-referral law (Stark Law), the federal Anti-Kickback Statute, and state analogs. He represents hospitals and health systems, ambulatory surgery centers, post-acute care providers, and physician practices, along with their strategic and financial sponsors, regularly serving as healthcare regulatory counsel for transactions, enforcement actions, and internal investigations, and advising on day-to-day operations. Before entering private practice, Justin was a trial attorney in the Massachusetts public defender’s office.

*Justin Brown is admitted to practice in Alabama and Massachusetts; Tennessee bar application pending

Photo of Dee Harleston Dee Harleston

Dee Harleston provides healthcare regulatory counsel on mergers, acquisitions, compliance, and operational matters. He also represents healthcare-focused private equity clients and their portfolio companies in buy-side and sell-side mergers and acquisitions. In addition, Dee advises clients related to compliance with federal healthcare laws…

Dee Harleston provides healthcare regulatory counsel on mergers, acquisitions, compliance, and operational matters. He also represents healthcare-focused private equity clients and their portfolio companies in buy-side and sell-side mergers and acquisitions. In addition, Dee advises clients related to compliance with federal healthcare laws such as HIPAA, AKS, Stark Law, and CMP and in matters of medical licensure.

Photo of Stewart Kameen Stewart Kameen

Stewart Kameen advises healthcare clients on all aspects of federal and state healthcare laws and regulations, with a particular emphasis on fraud and abuse regulatory counseling, corporate compliance, internal investigations and government enforcement actions, qui tam litigation, and transactional matters. Stewart is able…

Stewart Kameen advises healthcare clients on all aspects of federal and state healthcare laws and regulations, with a particular emphasis on fraud and abuse regulatory counseling, corporate compliance, internal investigations and government enforcement actions, qui tam litigation, and transactional matters. Stewart is able to counsel providers drawing on his unique perspective informed by his experience working at the U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG).

Photo of Travis Lloyd Travis Lloyd

Travis Lloyd focuses on complex healthcare regulatory matters. He represents a broad range of healthcare industry clients, including hospitals and health systems, ambulatory surgery centers, post-acute providers, behavioral health providers, and physician practices, as well as their strategic partners. He has significant experience…

Travis Lloyd focuses on complex healthcare regulatory matters. He represents a broad range of healthcare industry clients, including hospitals and health systems, ambulatory surgery centers, post-acute providers, behavioral health providers, and physician practices, as well as their strategic partners. He has significant experience in the areas of fraud and abuse, reimbursement, and health information privacy and security, as well as in the licensure, certification, and accreditation of healthcare facilities. His work has earned numerous noteworthy plaudits, including selection by Law360 as one of five “Rising Stars” in healthcare across the country in 2018 and selection by Bloomberg Law for its inaugural “They’ve Got Next” series in 2021.

Photo of Bill Mathias Bill Mathias

Bill Mathias advises healthcare companies on complex fraud and abuse and Stark Law issues.  He draws on over two decades of experience to address thorny healthcare regulatory questions.  He regularly assists clients with internal and government investigations and corporate compliance matters.

Photo of Jennifer Michael Jennifer Michael

Jennifer Michael draws on her experience as the former Chief of the Industry Guidance Branch at the U.S. Department of Health and Human Services (HHS), Office of Counsel to the Inspector General (OCIG) to help healthcare providers and life science companies avoid potential…

Jennifer Michael draws on her experience as the former Chief of the Industry Guidance Branch at the U.S. Department of Health and Human Services (HHS), Office of Counsel to the Inspector General (OCIG) to help healthcare providers and life science companies avoid potential fraud and abuse landmines and defend them in fraud and abuse investigations. Jennifer helps her clients structure their arrangements to comply with the federal Anti-Kickback Statute (AKS), the federal Civil Monetary Penalty (CMP) law, and other state and federal fraud and abuse laws and navigate government investigations under the federal False Claims Act (FCA).

Photo of Christine Morse Christine Morse

Christine Morse advises a wide range of healthcare companies on fraud and abuse claims, reimbursement issues and regulatory compliance. She has extensive experience advising provider organizations on key federal healthcare laws, such as the Stark Law, the Anti-Kickback Statute (AKS) and the False…

Christine Morse advises a wide range of healthcare companies on fraud and abuse claims, reimbursement issues and regulatory compliance. She has extensive experience advising provider organizations on key federal healthcare laws, such as the Stark Law, the Anti-Kickback Statute (AKS) and the False Claims Act (FCA). Christine also has deep knowledge the federal 340B Drug Pricing Program.

Photo of Heather Pearson Heather Pearson

Heather Pearson provides healthcare regulatory and transactional counsel as it relates to compliance, operational matters, and mergers and acquisitions. Heather draws on her experience as a public health analyst at RTI International, focusing on program evaluation and health system financing for CMS, and…

Heather Pearson provides healthcare regulatory and transactional counsel as it relates to compliance, operational matters, and mergers and acquisitions. Heather draws on her experience as a public health analyst at RTI International, focusing on program evaluation and health system financing for CMS, and her judicial clerkships in the Minnesota Court of Appeals and the U.S. District Court for the Northern District of Indiana. During law school, she summered at the Center for Health Law & Policy Innovation at Harvard Law School and in the Office of the Chief Counsel at the FDA.

Photo of Brianna Powell Brianna Powell

Brianna Powell provides healthcare regulatory counsel to a wide range of clients, including physician groups, hospices, hospital systems, long-term care providers, and private equity firms. Brianna advises clients on an array of complex regulatory issues.

Photo of Page Smith Page Smith

Page Smith provides healthcare regulatory counsel as it relates to compliance, operational and transactional matters.