decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Special Advisory Bulletins / OIG Special Advisory Bulletin 01-1_June 27, 2001 / Questionable Practices
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Article Overview
This article summarizes an OIG advisory bulletin focused on warning providers about problematic consultant conduct in the Medicare and other federal health care program environment. It covers broad categories of misleading marketing, unrealistic promises, encouragement of abusive billing or documentation practices, and discouragement of compliance activities. The bulletin is relevant to providers, compliance personnel, billing and reimbursement consultants, and anyone involved in health care program integrity or internal compliance oversight.
Why This Topic Matters
It helps organizations recognize consultant behaviors that may signal compliance risk and potential exposure under federal fraud and abuse authorities. The bulletin also underscores the importance of internal auditing, self-review, and other preventive compliance measures.
Article Sections
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Illegal or misleading representations
Discusses types of consultant statements and marketing claims that can misrepresent relationships with federal health care agencies or imply unauthorized endorsement. It also references federal restrictions on use of certain agency names and symbols.
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Promises and guarantees
Covers consultant assurances about results that may be unrealistic or unsupported, including concerns about improper means used to satisfy those promises.
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Encouraging abusive activities
Describes categories of consultant conduct that may encourage abusive or improper practices affecting billing, reimbursement, documentation, or program integrity.
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Discouraging compliance efforts
Addresses consultant messages that discourage internal review, auditing, or other voluntary compliance activities and notes the role of self-review in compliance programs.
What You Will Learn
- The main categories of consulting-related practices highlighted by the OIG as problematic
- How the bulletin frames risks related to marketing, promises, billing, documentation, and compliance oversight
- Why internal auditing and self-review are emphasized in federal health care program compliance
- Who should pay attention to consultant conduct in the context of Medicare and related programs
Who Should Read This
- Providers
- Compliance officers
- Billing and reimbursement staff
- Consultants
- Health care administrators
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