News & Analysis as of

Department of Health and Human Services (HHS) Pay-Per-Click

Health Care Compliance Association (HCCA)

Hospital, Doctors Pay $3M to Settle CMPL Case Over Cath Lab Lease

Report on Medicare Compliance 30, no. 4 (February 1, 2021) - Saint Peter’s University Hospital and New Brunswick Cardiac Cath Lab LLC in New Jersey have agreed to pay $3.04 million to settle a civil monetary penalty case...more

Jones Day

OIG Approves Online Directory’s Per-Click Fees, Signaling Growing Acceptance of Healthcare Technology

Jones Day on

The Situation: The Department of Health and Human Services ("HHS"), Office of Inspector General ("OIG") released an advisory opinion providing new insight into the evaluation of fraud and abuse risks of per-click fee...more

Manatt, Phelps & Phillips, LLP

OIG Advisory Opinion Permits Charging Per-Click and Per-Booking Fees

On September 10, 2019, the Office of Inspector General (OIG) of the federal Department of Health and Human Services posted OIG Advisory Opinion 19-04 (the Opinion), which addressed two proposed arrangements between providers...more

Robinson+Cole Health Law Diagnosis

HHS Issues Favorable Advisory Opinion for Online Healthcare Directory Charging Per-Click Fees

On September 5, 2019, the Department of Health and Human Services (HHS) Office of the Inspector General (OIG) issued OIG Advisory Opinion 19-04 ( Advisory Opinion). The Requestor asked OIG if providing an online healthcare...more

K&L Gates LLP

The “Cross-Your-Fingers-And-Hope-It-Goes-Away” School of Statutory Interpretation”: Recent D.C. Circuit Opinion Orders HHS To...

K&L Gates LLP on

On June 12, 2015, the U.S. Court of Appeals for the District of Columbia (the “Court”) issued an opinion questioning the Department of Health & Human Services’ (“HHS”) interpretation of congressional intent when it...more

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