In prior posts, we discussed some of the common due diligence and compliance issues for ketamine clinics (see here and here). In this post, we discuss a healthcare compliance plan and the importance of having one in place for ketamine clinics. The Department of Health and Human Services (“HHS”) (which houses, among other agencies, the Centers for Medicare & Medicaid Services or “CMS”) has a department named the Office of Inspector General (the “OIG”). As noted on the OIG’s website:
HHS OIG is the largest inspector general’s office in the Federal Government, with approximately 1,600 dedicated to combating fraud, waste and abuse and to improving the efficiency of HHS programs. A majority of OIG’s resources goes toward the oversight of Medicare and Medicaid — programs that represent a significant part of the Federal budget and that affect this country’s most vulnerable citizens. Our government oversight extends to programs under other HHS institutions, including the Centers for Disease Control and Prevention, National Institutes of Health, and the Food and Drug Administration.
OIG is one of the primary regulatory agencies for fighting fraud and abuse in the healthcare industry. If a healthcare provider takes federal reimbursement (e.g., Medicare, Medicaid, VA, etc.) then