OIG solicits modifications to safe harbor enforcement policies

One of the provisions of the Health Insurance Portability and Accountability Act of 1996 requires the Office of the Inspector General (OIG) to seek proposals and recommendations regarding OIG Medicare/Medicaid enforcement policies each year. The OIG is required to report to Congress on the recommendations it receives and the action it decides to take on them. One policy that the OIG specifically is seeking input on relates to safe harbors. The enforcement policy on safe harbors is of particular interest to healthcare providers seeking to integrate because it allows them to request modifications that will facilitate integration. Providers in integrated delivery systems that have legitimate business arrangements but that do not qualify for existing safe harbors can use the OIG's invitation as an opportunity to make a case for safe harbor protection.