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OIG OKs Physician Consultant Gift Card Arrangement

On January 3, 2024, the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) published OIG Advisory Opinion No. 23-15 (the “Opinion”), which addresses a request from a consulting company (the...more

Compliance Guidance, Part II: Opportunity to Provide Feedback

On February 21, 2024, the Office of the Inspector General (OIG) announced that it anticipates that the first two industry segment-specific compliance program guidance publications will likely be coming out in 2024 and will...more

2024 Compliance Guidance from the OIG: Part I

On November 6, 2023, for the first time since 2008, the US Department of Health and Human Services (“HHS”) Office of the Inspector General (“OIG”) issued comprehensive “General Compliance Program Guidance” (“GCPG”) for all...more

The Value Based Enterprise Safe Harbors and Exceptions

In recognition that the prior versions of the Stark Law and Anti-Kickback Statute (AKS) rules were not designed for a value-based health care delivery system, the new value-based safe harbors and exceptions (released in late...more

CMS Publishes New No Surprises Act “Consumer-Friendly” Resources Webpage

Providers should be aware consumers now have access to CMS resources that help them understand their rights under the No Surprises Act (NSA). In general, the NSA protects healthcare consumers from receiving surprise medical...more

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