William Mathias

William Mathias

Ober|Kaler

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OIG Approves Wholly Owned Group Purchasing Organization

In Advisory Opinion 16-06, the Office of Inspector General (OIG) approved a proposal whereby the ownership of a group purchasing organization (GPO) would be restructured so that the GPO will be wholly owned by the same...more

6/6/2016 - Anti-Kickback Statute Fraud and Abuse GPOs Health Care Providers OIG Parent Corporation Subsidiaries

OIG Approves Free Transportation and Lodging for Certain, Low-Income Pregnant Women - Advisory Opinion 16-02

On March 1, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 16-02 [PDF], approving an academic medical center's (AMC's) provision of free transportation and lodging...more

3/10/2016 - Advisory Opinions Anti-Kickback Statute Civil Monetary Penalty Free Health-Related Services Health Care Providers HHS Hospitals OIG Pregnancy

OIG Approves Charitable Program Providing Financial Assistance for MRIs in Advisory Opinion 15-14

On November 13, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-14. The Arrangement at issue is a charitable program designed to assist financially needy...more

2/17/2016 - Advisory Opinions Anti-Kickback Statute Charitable Organizations Civil Monetary Penalty Inducements Medicaid Medicare MRI OIG Patient Assistance Programs

OIG Approves Another Patient Assistance Program in Advisory Opinion 15-16

On December 28, 2015, the Office of Inspector General (OIG) approved another patient assistance program in Advisory Opinion 15-16. The OIG analyzed contributions to a private charitable organization under the anti-kickback...more

2/15/2016 - Advisory Opinions Anti-Kickback Statute Charitable Organizations Civil Monetary Penalty Inducements OIG Patient Assistance Programs Prescription Drugs

Charity's Patient Assistance Program Passes OIG Muster in Advisory Opinion 15-17

On December 28, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued OIG Advisory Opinion 15-17, approving a charity’s proposal to unveil a new patient assistance program dedicated to...more

2/12/2016 - Advisory Opinions Anti-Kickback Statute Charitable Organizations Civil Monetary Penalty Inducements OIG Patient Assistance Programs Prescription Drugs

OIG Issues (Another) Favorable Advisory Opinion Regarding Medigap/Preferred Hospital Network Arrangement in Advisory Opinion 16-01

On January 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 16-01, approving yet another insurer’s proposed contract with a preferred hospital network. The...more

2/11/2016 - Advisory Opinions Anti-Kickback Statute Discounts Inducements Medicare Medigap OIG Preferred Hospital Networks Arrangement

OIG Approves Home Health Provider's Free Introductory Visit Policy

On August 6, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a for-profit home health provider’s policy to offer free introductory visits to...more

9/28/2015 - Advisory Opinions Anti-Kickback Statute Civil Monetary Penalty Free Health-Related Services Health Care Providers Home Health Care OIG Sanctions

OIG Approves Limited, Free Drug Program

On August 12, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-11, approving two pharmaceutical manufacturers’ free starter drug program. Citing the limited scope...more

8/27/2015 - Anti-Kickback Statute Cancer Cost-Sharing Free Health-Related Services Free-Drug Programs Health Insurance HHS Medicare Part D OIG Patients Pharmaceutical Industry Pharmacies

Stark Regulations: Technical Revisions

The proposed Physician Fee Schedule for CY 2016 includes multiple technical revisions to the regulations implementing the Stark law. These revisions appear to be designed to provide greater clarity and flexibility with...more

7/22/2015 - Anti-Kickback Statute CMS Commercial Leases Exceptions Physician Compensation Arrangements Physician Fee Schedule Remuneration Self-Referral Disclosure Protocol Signatures Stark Law Timeshare

Again, the OIG Approves a Medigap Policy Contract with Preferred Hospital Networks

On June 12, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-08. This opinion continues the well-established pattern of favorable advisory opinions which...more

7/3/2015 - Anti-Kickback Statute Civil Monetary Penalty Fraud and Abuse Health Insurance HHS Hospitals Medigap OIG Preferred Hospital Networks Arrangement

OIG Approves Subsidies to Medicare Beneficiaries Provided by a Clinical Research Study

On May 28, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a medical device manufacturer’s proposed arrangement to provide subsidies to certain...more

6/23/2015 - Advisory Opinions Anti-Kickback Statute Civil Monetary Penalty Clinical Trials HHS Medical Devices Medicare OIG Subsidies

OIG Approves Free Diapers and Playpen in Connection with Medicaid Program Promoting Pre- and Post-Natal Care

On January 26, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving an entity’s practice of advertising and providing free diapers and free portable...more

2/16/2015 - Advertising Advisory Opinions Anti-Kickback Statute Children's Products Civil Monetary Penalty Free Health-Related Services HHS Medicaid OIG Pregnancy Preventive Health Care

ACO Fraud and Abuse Waivers Extended Through November 2, 2015

On October 17, 2014 the Centers for Medicare and Medicaid (CMS) and Office of Inspector General (OIG) within the Department of Health and Human Services published a continuation notice in the Federal Register extending the...more

11/21/2014 - ACOs Anti-Kickback Statute CMP Law CMS Fraud and Abuse HHS OIG Shared Savings Program Stark Law Waivers

Discount Drug Program Passes OIG Scrutiny

On July 28th, 2014, the Department of Health and Human Services, Office of Inspector General (OIG) released favorable advisory opinion 14-05, concluding that a pharmaceutical manufacturer’s direct-to-patient discounted, cash...more

8/14/2014 - Anti-Kickback Statute Civil Monetary Penalty HHS OIG Pharmaceutical Industry Prescription Drugs

OIG Supplemental Special Advisory Bulletin Raises New Concerns About Independent Charity Patient Assistance Programs

In an effort to address new concerns about the independence of charity patient assistance programs (PAPs), the Office of Inspector General (OIG) released its Supplemental Special Advisory Bulletin: Independent Charity Patient...more

5/30/2014 - Anti-Kickback Statute Healthcare Medicare Medicare Part D OIG Patient Assistance Programs Pharmaceutical Industry

Dodging the AKS: Marketplace Plans Are Not "Federal Health Care Programs"

In an October 30th letter addressed to Congressman Jim McDermott, the Department of Health and Human Services (HHS) Secretary, Kathleen Sebelius, left little to interpretation: Qualified health plans (QHPs) purchased through...more

11/8/2013 - Affordable Care Act Anti-Kickback Statute CMS False Claims Act (FCA) Health Insurance Exchanges Healthcare Healthcare Reform HHS OIG Premiums Qualified Health Plans

2013 Healthcare Fraud and Abuse Bootcamp Webinar Series, Part V: Compliance

Bill Mathias of Ober|Kaler's Health Law Group presented on compliance as a part of the 2013 Healthcare Fraud and Abuse Bootcamp Webinar Series sponsored by the American Health Lawyers Association. This webinar...more

6/17/2013 - Anti-Kickback Statute Audits CMS Compliance Documentation False Claims Act (FCA) Healthcare Fraud Internal Investigations Medicaid Medicare OIG Penalties Self-Disclosure Requirements Stark Law

OIG Calls PODs "Inherently Suspect"

Making its most strongly worded statement to date, the Department of Health and Human Services Office of Inspector General (OIG) issued a Special Fraud Alert on Physician-Owned Entities on March 26, 2013, calling...more

3/29/2013 - Ambulatory Surgery Centers Anti-Kickback Statute Client Referrals Fraud Healthcare Hospitals Joint Venture Manufacturers Medical Devices OIG Physician-Owned Distributors Physicians

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