HHS-OIG Year in Review: Despite Challenges Posed by the Pandemic, 2020 Saw an Uptick in Enforcement Action | Skadden, Arps, Slate, Meagher & Flom LLP
aaaa Notable CIAs and Trends Amendments. Like the number of CIAs, the number of CIA amendments also increased in 2020. Although the HHS-OIG typically enters into one or two amendments per year, 2020 saw seven such agreements. One amendment postponed the CIA’s effective date to account for the demands of the pandemic and another added a party to account for corporate restructuring. One aa highlighted the HHS-OIG’s close review of compliance programs, adding additional compliance obligations to address concerns regarding patient safety issues and CIA adherence. The majority of amendments (f...