CSHM MEDIA RESPONSE TO OIG EXCLUSION LETTER In a letter dated March 7, 2014, CSHM LLC (“CSHM”) received a notice of exclusion from federal health care programs from the Office of Inspector General of the Department of Health and Human Services (OIG). The notice of exclusion does not apply to any individual employee or the Dental Centers and Practice Owners, but to the CSHM LLC corporate entity only. The exclusion notice does not prevent any Center from providing dental services to its patients. If the exclusion should go into effect, it means that CSHM may not continue with some or all of its current responsibilities under its Management Services Agreement (MSA) and this may affect administrative services related to Center operations. The exclusion notice is based on the OIG’s determination that CSHM has violated some terms of the Corporate Integrity Agreement (CIA) that has been in place for the management company and its predecessor since January 2010. CSHM assumed the CIA in June, 2012 and it is well known that it has implemented the CIA provisions within the Centers and generally since that time. Many Center owners and employees have met the Independent Quality Monitor (IQM) and CSHM’s compliance staff over the last 18 months as the company was implementing the CIA’s provisions. Generally, the alleged violations related to certain delayed reporting of a few adverse clinical events, failure to undertake certain training in 2012 before CSHM assumed the CIA, and the omission of two adverse events on the CIA disclosure log, though over 1,200 events were successfully placed on the disclosure log for processing. CSHM believes strongly that it has substantially and in good faith implemented the CIA at a great cost in resources and with the important cooperation of the Centers and its health care professionals, particularly on enhancing dental clinical standards. The OIG’s proposed determination to exclude CSHM for some non-compliance with its CIA is an unduly harsh and an unprecedented response to expected and common difficulties in implementing a very complex CIA that has novel and innovative administrative, process and clinical requirements. CSHM intends to appeal the notice of exclusion and file a request for hearing with the Department Appeals Board. During the appeals process, the exclusion will be stayed, and we will continue to provide business, administrative and support services to 53 associated dental centers in 19 states and the District of Columbia, pursuant to our management services agreements. The legal process will take an indeterminate period of time. In the interim, CSHM will continue to perform normal operations and will continue to provide our internal and external constituents with up-to-date information. Should you have questions regarding this matter, please contact a member of our communications team at Lovell Communications: Paula Lovell: 615-297-7766 / lovell@lovell Rosemary Plorin: 615-297-7766 / rosemary@lovell Perry Hall: 615-297-7766 / perry@lovell
Posted on: Wed, 12 Mar 2014 18:18:23 +0000
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