One easy way to provide some spe- cialized compliance training and awareness is to give your Board of
Directors, Audit & Compliance Committee,
Compliance Executive Committee, and your
Compliance Operations Committee(s) a
one-page list of what other organiza-
tions have recently self-disclosed.
This may generate some discussion
about what controls your organiza-
tion has in place to comply with these
same areas. This one-page list could
include, for example, a table like this
one that you could generate from the
OIG website at http://bit.ly/2lsK5KZ:
by Catherine Boerner, JD, CHC
What is everyone self-disclosing?
Catherine Boerner ( firstname.lastname@example.org) is President at
Boerner Consulting, LLC located in New Berlin, WI. /in/catherineboerner
Employed an individual that it knew or should have known was excluded from participation in federal
Knowingly presented to federal healthcare programs claims for services that it knew or should have known were not
provided as claimed and were false or fraudulent. Specifically, submitted claims for outpatient pediatric primary care
services that it knew or should have known were furnished by medical students without required supervision.
Submitted claims to federal healthcare programs for ambulance transportation services provided an employee as if that
employee had the EMT-Intermediate certification when, in fact, the employee had the EMT-Basic certification.
(1) Improperly submitted claims to Medicare related to certain inpatient admissions; ( 2) received remuneration in
the form of inpatient computed tomography equipment and services provided below fair market value (FMV) from an
independent diagnostic testing facility (IDTF) and paid remuneration to the IDTF in the form of below FMV medical office
space and support services; and ( 3) improperly reported illegal remuneration from hospital vendors paid to a former
CEO on hospital’s cost reports then used by the Medicare and Medicaid program to calculate reimbursement rates to
MPH, resulting in overpayments.
Submitted claims to federal healthcare programs for ambulance transportation services provided to beneficiaries which
were improper because ambulance company did not obtain the required beneficiary signatures.
Submitted false claims to Medicare for: (1) services rendered by providers who were not enrolled in the Medicare program; and ( 2) services rendered by non-physician providers as “incident to” when the "incident to" requirements under
Medicare were not met.
Submitted Chronic Care Management services under Current Procedural Terminology (CPT) Code 99490 that were not
provided or that were not provided as required by CPT Code 99490.
Submitted claims to Medicare for allergen immunotherapy injections provided without the requisite
This is just one way to keep everyone
engaged and provide ongoing training on