On November 30, 2011, the OIG issued a favorable Advisory Opinion, No. 11-18, concerning a proposed arrangement that would facilitate the electronic exchange of information between health care practitioners, providers, and suppliers (the “Proposed Arrangement”). Although, the Proposed Arrangement potentially implicates the Anti-Kickback Statute and includes a per-click fee arrangement, the OIG advised that it would not subject the data management company (the “Requestor”) to administrative sanctions under the Anti-Kickback Statute. Continue reading
Category Archives: OIG Advisory Opinions
Summary of OIG Advisory Opinion 11-18
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Posted in Anti-Kackback, Fraud and Abuse, Health Care, OIG, OIG Advisory Opinions, Physicians, Regulatory Compliance
OIG Advisory Opinion No. 11-17 – Physician – Lab Arrangement Could be an AKS Issue
On November 23, 2011, the OIG issued Advisory Opinion No. 11-17, which concluded that a proposed arrangement between primary care physicians (the “Physicians”) and a laboratory management company (the “Lab Company”) could potentially generate prohibited remuneration under the Anti-Kickback Statute. Continue reading
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Posted in Anti-Kackback, Clinical Laboratory, Fraud and Abuse, Health Care, Medicare, OIG, OIG Advisory Opinions, Out-Patient Care, Physicians
OIG Advisory Opinion 11-16 – Hospital’s Provision of Transportation, Lodging, and Meal Assistance to Patients and their Family is OK
On November 15, 2011, the OIG released Advisory Opinion 11-16. In this new advisory opinion, the OIG reviewed a non-profit Hospital’s domiciliary services program that provides transportation, lodging, and meal assistance to certain patients and their family members. The OIG issued a favorable opinion of the arrangement and concluded that (i) the Arrangement does not constitute grounds for the imposition of civil monetary penalties; and (ii) while the Arrangement could potentially generate prohibited remuneration under the Anti-Kickback Statute, the OIG will not impose administrative sanctions. Continue reading
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Posted in Acute Care, Anti-Kackback, Fraud and Abuse, Health Care, Health Care Providers, Hospital, Medicare, OIG, OIG Advisory Opinions
Benesch
Ari J. Markenson, JD, MPH
Janet K. Feldkamp RN BSN LNHA CHC JD
Robert W. Markette, Jr. CHC
W. Clifford Mull
Frank W. Carsonie
Daniel J. O'Brien
Benjamin J. Parsons
Meredith L. Rosenbeck
Alan E. Schabes
