The Department of Health and Human Services Office of Inspector General (OIG) recently issued education materials designed to educate medical students, residents and fellows on Medicare and Medicaid fraud, waste and abuse. The publication, titled A Roadmap for New Physicians: Avoiding Medicare and Medicaid Fraud and Abuse, summarizes the five main federal fraud and abuse laws, including the False Claims Act, Anti-kickback Statute, Stark Law, Exclusion Statute and Civil Monetary Penalties Law. The 31-page Roadmap also describes how physicians should comply with these laws in their dealings with payers, vendors and other providers, and provides detailed case examples of practices that violate the federal fraud and abuse laws. The Roadmap is available here.1
With respect to payer relationships, the Roadmap addresses accurate coding and billing, physician documentation, enrolling as a Medicare and Medicaid provider, prescription authority and assignment issues in Medicare reimbursement. For vendor relationships, the Roadmap examines free samples, relationships with the pharmaceutical and medical device industries, transparency in physician-industry relationships, conflicts-of-interests disclosures and continuing medical education. Finally, the Roadmap explores relationships with other providers, including physician investment in healthcare business ventures, physician recruitment and medical director arrangements.
The OIG developed the Roadmap in response to its survey findings that more than 90 percent of medical school deans and hospitals offering residency and fellowship programs reported an interest in OIG-developed fraud and abuse training materials. The OIG’s survey results also indicated that 44 percent of medical schools and more than two-thirds of hospitals offering residency and fellowship programs reported providing some form of fraud and abuse training to their students or trainees in 2010. The OIG’s Roadmap was developed to provide medical schools and hospitals with a consistent starting point to build their fraud and abuse training programs for medical students, residents and fellows. The OIG’s survey findings are detailed in its October 2010 report, Medicare and Medicaid: Fraud and Abuse Training In Medical Education, available here.2