On May 25, 2022, OIG posted an Advisory Opinion analyzing a medical group’s proposal to employ an individual excluded from participation in federal health care programs to perform marketing tasks related to workers’ compensation (WC) programs. OIG determined that the medical group’s proposed arrangement would not constitute grounds for the imposition of sanctions under the civil monetary penalty provision at section 1128A(a)(6) of the Social Security Act (the Act).
The medical group specializes in pain management, and most of its patients are treated for injuries covered by its state’s WC program. According to the medical group, none of these WC programs are federal health care programs.
In 2016, the excluded individual—who was a licensed chiropractor—pleaded guilty to conspiracy, in violation of 18 U.S.C. § 371, in relation to receiving illegal kickbacks for referring WC patients to a certain hospital for spinal surgery. In 2017, the state’s WC department suspended the excluded individual from participating in the state’s WC system as a provider. OIG excluded the individual in 2021, pursuant to section 1128(a)(3) of the Act.
Under the proposed arrangement, the medical group would establish the excluded individual’s employment as a WC payor relations representative. In this role, the excluded individual’s primary job responsibility would be marketing the medical group’s services to WC payors, and attorneys who work with persons covered by WC payors, by explaining the...
On May 10, a Muslim man called Arif Khan was assaulted inside a hotel in Madhya Pradesh’s Bhopal. Khan was with a Hindu woman at the hotel when men reportedly linked to the Bajrang Dal entered the ...