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HHS OIG Audit Report on Institutional Status of Medicare + Choice Enrollees

Client Alert | 1 min read | 04.12.03

The HHS Office of Inspector General has released an April 11, 2003 audit report on Medicare + Choice plan institutional status classifications of Medicare + Choice enrollees. Institutional status results in a higher monthly capitation to the plan. The OIG report faults the audited plan for assigning institutional status to patients who were in Medicare certified facilities, but not occupying a bed in a distinct Medicare certified portion of the facility. The OIG audit report rejects Coventry's argument that CMS instructions and the applicable CMS policy letter require only that the beneficiary reside in a certified facility, and not that the bed itself be in beds that the facility has allocated or identified as within a certified portion of the facility. The OIG auditors' position appears contrary to informal guidance previously provided by CMS to health plans. Here is a link to the audit report. http://oig.hhs.gov/oas/reports/region7/70200148.htm

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Client Alert | 3 min read | 03.12.26

DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy

On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”...