Lahey Health System Agreed to Pay $1.9 Million for Allegedly Violating the Civil Monetary Penalties Law by Employing an Excluded Individual

After it self-disclosed conduct to OIG, Lahey Health System, Inc. on behalf of its current subsidiaries and affiliates Lahey Clinic Hospital, Inc. (LCH), Northeast Senior Health Corporation, and Visiting Nurse Association of Middlesex-East, Inc. (collectively, Lahey), Massachusetts, agreed to pay $1,923,993 for allegedly violating the Civil Monetary Penalties Law provisions applicable to physician self-referrals and kickbacks. OIG alleged that Lahey received remuneration from home health agencies in the form of free administrative services related to discharge planning provided by the home health agencies staff serving as liaisons for their respective home health agency employers. Specifically, OIG contends that, without any written contract, some of the functions performed by the home health agency employees were functions that ordinarily would have been performed by LCH discharge planners or other LCH staff, and those services constituted improper remuneration.

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