• NEW REQUIREMENT UNDER HEALTH CARE BILL
o Section 6401 of the Patient Protection and Affordable Care Act (“PPACA”) grants to the Secretary of the Department of Health & Human Services (the “Secretary”) the authority to require health care providers to adopt compliance programs as a condition to enrollment or revalidation in the Medicare, Medicaid and CHIP programs.
o Section 6401 does not impose a specific deadline for designating the industry segments that will be subject to the mandatory compliance program requirement or for establishing the core elements of such compliance programs.
o A review of guidance previously provided by the Office of Inspector General (“OIG”) gives an indication of both the industry segments which may be subject to the mandatory compliance program requirement and the core elements of such compliance programs.
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