You lead a multi-disciplinary team that deals with compliance issues for GoodHealth, Inc., a large healthcare provider that owns four hospitals. Your team did some investigating, including internal audits and confidential interviews, and they found the following:

(1) One of the facilities rents imagining equipment from staff radiologists and that equipment is located in the radiologists' private, off-campus office;

(2) medical staff have been offered bonuses for increasing admissions and referrals;

(3) there are medical coding errors going five years back that represent millions of dollars of overcharges;

(4) medical errors are not being consistently reported; and,

(5) physician peer review for medical errors is not taking place in a consistent or timely manner.

Your team has concluded that it is in the best interest of GoodHealth, Inc. to self-report to the OIG. The team must present to the CEO. The CEO will submit the report to the Board of Directors. Be creative. How would you address the 5 areas be approached?

A Roadmap for New Physicians: Fraud and Abuse Laws:https://oig.hhs.gov/compliance/physician-education/01laws.asp

Comparison of Antikickback Statute and Stark Law:https://oig.hhs.gov/compliance/provider-compliance-training/files/starkandakscharthandout508.pdf

State False Claims Act Reviews:https://oig.hhs.gov/fraud/state-false-claims-act-reviews/index.asp

Health care corporate compliance:https://www.hcca-info.org/

Whistleblowing:http://www.stltoday.com/news/local/crime-and-courts/whistle-blowing-doctor-getting-award-from-the-fbi/article_a99c4241-b2cd-5faf-ae2b-8d5970dc88d8.html

https://oig.hhs.gov/fraud/docs/complianceguidance/Corporate%20Responsibility%20and%20Health%20Care%20Quality%206-29-07.pdf

https://oig.hhs.gov/fraud/docs/complianceguidance/040203corpresprsceguide.pdf

https://oig.hhs.gov/fraud/cia/agreements/Halifax_Hospital_03102014.pdf