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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Health

Date & Time
  • event Date

    Wednesday, March 12, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$297.00
CLE
ALL

This CLE webinar will guide practitioners through the U.S. Department of Health and Human Services Office of Inspector General's (HHS-OIG) recently published strategic plan to more closely monitor agency grants and contracts for fraud and mismanagement. The panel will provide an overview of the grants and contracts lifecycle along with the inherent risks of abuse in each. The panel will also offer best practices for compliance to mitigate the risk of enforcement action for contractor clients.

Faculty

Dennis Sapien-Pangindian
Senior Counsel
Epstein Becker & Green PC

As a litigation and regulatory attorney, Mr. Sapien-Pangindian draws on his enforcement experience at the U.S. HHS OIG to represent clients in a range of complex controversies. His practice focuses on government investigations, civil litigation, administrative law challenges, and regulatory compliance matters, with a particular emphasis on health care fraud and abuse, information blocking, grant fraud (e.g., research misconduct) issues, health care business disputes, and FOIA challenges. Mr. Sapien-Pangindian has substantial experience managing internal investigations concerning alleged violations of the Food, Drug, and Cosmetic Act, the Stark Law, the Anti-Kickback Statute, and the False Claims Act. He is also well-versed in the information blocking law and regulations that were promulgated under the 21st Century Cures Act. Mr. Sapien-Pangindian helps clients respond to U.S. DOJ and Medicaid Fraud Control Unit subpoenas and demands, develops investigation work plans, and designs and conducts compliance reviews tailored to clients’ needs.

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Andrea Castronova
Principal
Athena Compliance Partners

Ms. Castronova has over 25 years of experience in healthcare compliance and internal audit. She provides various compliance and HIPAA consulting services for various organizations. Ms. Castronova has presented for many professional organizations in the area of compliance effectiveness, compliance investigations, and statistical sampling and auditing. She is Certified in Healthcare Compliance through HCCA, a Certified HIPAA Compliance Officer through AIHC, and is a Certified Internal Auditor.

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Description

In FY 2023, HHS (excluding CMS) awarded approximately 142,000 grants totaling $148.6 billion and approximately 54,000 contracts totaling $31 billion. As fraud related to awards by HHS and other agencies continues to increase, HHS-OIG recently published a strategic plan for improving grant and contractual oversight. The agency's stated goals are to: (1) strengthen compliance with HHS award requirements throughout the grants and contracts life cycle; (2) promote award practices that achieve program outcomes; and (3) enhance public trust in HHS awards by mitigating fraud, waste, abuse, and mismanagement.

The agency acknowledges that each step in the grants and contracts lifecycle contains unique risks and vulnerabilities for fraud and mismanagement. For example, risks in the pre-award stage can include applicants seeking awards they are ineligible to receive or making financial arrangements to steer awards in their favor. Or in the post-award stage, risks include the misuse of awards due to inefficiencies, the claiming of unallowable expenditures, or fraud.

Therefore, the agency has created objectives for each of the stated goals to improve agency oversight including, for mitigating fraud and mismanagement, the increased use of criminal, civil, and administrative actions; suspension and debarment referrals; and follow-up of unimplemented recommendations.

Counsel should understand the agency's new guidance to assist their healthcare contractor clients with strict compliance and to minimize the risk of costly enforcement action.

Listen as our expert panel discusses HHS-OIG's strategic plan for the increased oversight of HHS-awarded grants and contracts. The panel will provide an overview of the grants and contracts lifecycle and risks of fraud and mismanagement in each. The panel will then discuss the agency's objectives for mitigating those risks, including possible enforcement action, and offer best practices for compliance to mitigate the risk of noncompliance.

Outline

  1. Introduction
    1. Purpose of HHS' new initiative
  2. Grants and contracts lifecycle and fraud/mismanagement risks inherent to each
    1. Pre-award
    2. Award
    3. Post-award
    4. Closeout
  3. Strategic plan: safeguarding the integrity of HHS grants and contracts
    1. Goals and objectives
      1. Strengthen compliance with requirements throughout the grants and contracts lifecycle
      2. Promote award practices that achieve program outcomes
      3. Enhance public trust in HHS awards by mitigating fraud, waste, abuse, and mismanagement
    2. Contractor compliance considerations
    3. Enforcement
  4. Lessons learned from recent high profile enforcement fraud actions
  5. Practitioner takeaways

Benefits

The panel will review these and other important considerations:

  • What is the purpose of HHS-OIG's strategic plan for increasing oversight of agency grants and contracts?
  • What vulnerabilities in the grants and contracts lifecycle increase the risk of fraud and mismanagement?
  • What are the agency's objectives in reducing the risk of fraud and mismanagement in the grants and contracts lifecycle? And what types of enforcement action may it use to reach those objectives?