Posts Tagged ‘advisory opinion’
OIG Gives Blessing to Gift Card Arrangement
Last month, the Office of Inspector General (OIG) published an advisory opinion in which it declined to impose sanctions for an arrangement under which the requestor provides gift cards to Medicare Advantage enrollees who complete an online learning program related to potential risks, benefits, and expectations relating to surgeries. The requestor stated that the program…
Read MoreOIG Advisory Opinion Okays Treatment-based Patient Incentives
A digital health company that uses smartphone and smart debit card technology to operate an incentive program for patients with substance use disorders was given a favorable advisory opinion by the Office of Inspector General for the Department of Health and Human Services (OIG) to provide patient incentives in the form of a debit card…
Read MoreOIG Advisory Opinion Finds Proposed Joint Venture Riddled with Problems
A contract therapy services company that provides management of day-to-day operations and therapy staffing for rehabilitation programs in long-term care communities (i.e., skilled nursing facilities, assisted living facilities, and full-service continuing care retirement communities) recently was advised by the HHS Office of Inspector General that a proposed joint venture arrangement presented a host of concerns…
Read MoreOIG Issues Four Advisory Opinions in December
The U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) cranked out four Advisory Opinions in the waning days of 2020. On December 18, the watchdog agency gave its blessing to a management company that wants to provide Medicaid enrollment application assistance services to certain individuals and affiliated SNFs and an…
Read MoreOIG Offers Advisory Opinions on COVID-19-Related Arrangements, But …
The COVID-19 pandemic has resulted in a unique set of circumstances for many healthcare providers. Delivering quality patient care, while at the same time trying to navigate existing laws and regulations, has many providers questioning whether the arrangements they are making in response to this public health emergency will not get them into trouble with…
Read MoreOIG Gives Drug Manufacturer Green Light to Cover Patient Expenses
The Office of Inspector General (OIG) in a Jan. 21 Advisory Opinion (No. 20-02) approved an agreement under which a pharmaceutical manufacturer would provide travel, lodging and other expenses to financially needy patients prescribed the manufacturer’s personalized medication. In doing so, the OIG noted that such an arrangement could potentially violate the Anti-Kickback Statute, (AKS)…
Read MoreOIG: Complimentary In-Home Care Permitted, Despite Potential Anti-Kickback Violation
A recent advisory opinion issued by the U.S. Department of Health and Human Services Office of the Inspector General has given a medical center the go-ahead to provide free in-home care to reduce re-admissions, despite a prohibition against giving patients handouts that might influence care decisions. The OIG advisory opinion is in response to a…
Read MoreOIG: Pediatric Clinic Can Provide Routine Cost-Sharing Waivers
A pediatric clinic that provides medical, psychiatric and dental care to low-income children can waive cost-sharing amounts for patients in financial need, even though the arrangement does not meet the regulatory exception for permitted waivers of cost-sharing amounts under the Civil Monetary Penalties Law, according to an Advisory Opinion issued by the Health and Human…
Read MoreOIG Opinion Applies Access to Care Exception
Can a hospital system provide free or reduced-cost lodging and meals to certain financially needy patients, or would such an arrangement (a) constitute either a violation of the federal anti-kickback statute or (b) constitute grounds for the imposition of civil monetary penalties because it would violate a provision of the Social Security Act that prohibits…
Read MoreOIG Says Free Labeling of Test Tubes, Collection Containers Could Violate Anti-Kickback Laws
The Office of Inspector General (OIG) recently issued an advisory opinion suggesting that a laboratory’s proposal to label test tubes and specimen collection containers at no cost to dialysis facilities could constitute remuneration under the anti-kickback statute and result in potential sanctions. The opinion issued this month came at the request of an unnamed laboratory…
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