Lawrence Vernaglia Comments on HHS OIG Approval of Community Health Center Proposal

Foley & Lardner LLP partner Lawrence Vernaglia commented on the U.S. Department of Health and Human Services (HHS) Office of Inspector General’s approval of a recent proposal in the Report on Medicare Compliance article, “OIG OKs Health Center’s Plan to Link Social Services to Primary Care.”

“This is the kind of arrangement that HHS should be excited to approve,” Vernaglia said, explaining the OIG’s advisory opinion offers two key takeaways for providers.

“First, when considering internal referrals where there is any risk of a perceived remuneration, offering a list of unrelated potential providers is always a conservative course of action to be considered,” he continued.

Secondly, Vernaglia said that many providers face situations with underserved patients who required additional support. He encouraged other providers to think about those programs “through a compliance lens,” suggesting the implementation of safeguards “against undue influence,” including things like not advertising programs, offering them only to existing patients, and taking steps to confirm patient need.