William Mathias

William Mathias

Ober|Kaler

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OIG Advisory Opinions Provide Some Helpful Guidance

In spite of a slow start, the OIG has issued a number of interesting advisory opinions to date in 2013. Here are a few of the highlights. The OIG reiterated its long-standing concern about arrangements which “carve out”...more

7/19/2013 - Advisory Opinions Health Insurance Healthcare Hospitals Medicare Medigap OIG

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

OIG Permits Gainsharing under Co-management Agreement

In Advisory Opinion 12-22, the OIG permitted a hospital to make payments to a cardiology group as part of a co-management agreement that for all intent and purpose are gainsharing payments. The extent to which this represents...more

1/31/2013 - Co-Management Fee Agreements Gainsharing Hospitals OIG

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