On March 30, 2020, OIG released a message to health care providers reinforcing OIG’s continued focus on aggressively pursuing bad actors exploiting the COVID-19 crisis but also praising the hard work and dedication of the frontline providers who are serving heroically in this crisis. This is in follow-up to our previous COVID-19-related guidance pertaining to fraud investigations and enforcement activities, which Hall Render summarized in a previous alert. In OIG’s efforts to further support health care providers, OIG’s Principal Deputy Inspector General, Christi A. Grimm, indicated that, to the extent possible, OIG will try to minimize burdens on providers and be flexible where it can. In doing so, OIG will take into account burdens on providers, as well as the safety of patients and the health care workforce. OIG stated that it will evaluate conduct during this emergency that may be subject to OIG administrative enforcement and will carefully consider the context and intent of the parties when assessing whether to proceed with any enforcement action.
Additionally, health care organizations that currently have ongoing matters with OIG, such as Corporate Integrity Agreements (“CIAs”), are encouraged to ask their OIG contact for any extensions or relief needed related to deadlines and reporting obligations. OIG has indicated a willingness to work with organizations on a reasonable solution, including proceeding in the normal course if that is the provider’s preference. Finally, OIG encouraged electronic submissions of any materials that would ordinarily be mailed since mail service has been temporarily suspended due to the COVID-19 crisis.
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