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OIG Says Proposed Surgery Monitoring Arrangement May Violate Kickback Statute

On August 18, the Office of Inspector General in the Department of Health and Human Services (“OIG”) issued Advisory Opinion 23-05 in which it concluded that a proposed arrangement involving the formation of a company...more

Final Rule Ends COVID Vaccine Mandate in CMS-Certified Facilities

The United States Department of Health and Human Services (“HHS”), through the Centers for Medicare and Medicaid Services (“CMS”), published a final rule on June 5 (the “Final Rule”), which, among other important actions,...more

Proposed NY Legislation Requires DOH Approval of Health Care Entity Transactions

The landscape of health care transactions has been constantly evolving and that holds particularly true at present. Recently, the Health Law Observer highlighted new requirements for “change in ownership” transactions in New...more

Overview of HHS Guidance on Audio-Only Telehealth Services

The COVID-19 pandemic accelerated the evolution of the role of technology in medical care, giving rise to novel issues in the absence of formal governmental guidance. Responding to certain challenges brought on by the...more

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