Anti-Kickback Statute, Hospitals

Hospital And Physician Compliance With Anti-Kickback And Stark Restrictions

by Michael Volkov on 4/24/2013

A bribe is a bribe. It is not as easy as it sounds. Not all payments of money or transfers of value are bribes. The FCPA tells us that. It is even more complicated when trying to navigate Anti-Kickback and Stark law...more

Rural Hospital Cardiac Catheterization Lab Cost Savings Program issued favorable OIG Advisory Opinion

by Danielle Trostorff | Baker, Donelson, Bearman, Caldwell &... on 4/4/2013

On December 31, 2012 the U.S. Department of Health and Human Services Office of Inspector General ("OIG") issued a favorable Advisory Opinion No.12-22 for a hospital cardiology group compensation arrangement that includes a...more

OIG Calls PODs "Inherently Suspect"

by Julie Kass, William Mathias, Sanford Teplitzky | Ober|Kaler on 3/29/2013

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

OIG Approves Co-Management Arrangement

by Marshall Burack | Akerman Senterfitt on 1/30/2013

Hospitals across the country have been actively seeking to align physician interests with the interests of the hospital, in order to provide high quality patient care in a more coordinated and efficient manner. Many hospitals...more

OIG Issues Advisory Opinion On Co-Management Incentive Compensation Arrangement

by Janice Anderson, T. Jeffrey Fitzgerald, Joan Killgore, Daniel Reinberg | Polsinelli on 1/23/2013

On January 7, 2012, the OIG posted Advisory Opinion No. 12-22 to address a co-management arrangement between a hospital and physicians that is designed to align incentives by offering compensation based on quality, service,...more

OIG Advisory Opinion Sheds Light On Pay-For-Performance Relationships Between Hospitals And Physicians

by Darby C. Allen, Donna S. Clark | BakerHostetler on 1/20/2013

On January 7, 2013, the HHS OIG released Advisory Opinion 12-22 concerning a rural hospital's (Hospital) proposal to pay a cardiology group (Group) a performance bonus for achieving certain patient service, quality and cost...more

OIG: Cardiac Catheterization Arrangement Between Hospital and Physicians Not Subject to Sanctions

by King & Spalding on 1/18/2013

On January 7, 2013, HHS OIG published a favorable advisory opinion on a management arrangement between a hospital and a cardiology group related to the provision of certain cardiac catheterization services at the hospital. ...more

OIG Provides Direction and CMS Seeks Direction Relating to Electronic Activities in the Health Care Delivery System

by Bruce D. Armon, Evan J. Foster | Saul Ewing LLP on 1/7/2013

The OIG recently posted an Advisory Opinion which concluded that a hospital's proposal to provide free access to an electronic interface between the hospital and area physicians for laboratory and diagnostic services was not...more

OIG Approves Hospital’s Electronic Interface Arrangement

by Theresa C. Carnegie, Kimberly J. Gold | Mintz Levin - Health Law on 12/21/2012

In OIG Advisory Opinion 12-20, the OIG determined that a proposed arrangement (the “Proposed Arrangement”) by a hospital (the “Requestor”) would not constitute grounds for the imposition of sanctions under the Anti-Kickback...more

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Anti-Kickback Statute › Hospitals