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Office of the Inspector General › Carve Out Provisions

Mintz - Health Care Viewpoints

OIG Issues Advisory Opinion Nixing Purchased Services Arrangement Between Certain Anatomic Pathology Laboratories

Mintz - Health Care Viewpoints on

Last week the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) issued Advisory Opinion 23-06 (AO), which advised that a proposed arrangement between certain laboratories for the purchase...more

Bass, Berry & Sims PLC

Expect the Expected: OIG Remains Suspicious of Suspect Contractual Joint Ventures in Advisory Opinion Involving IONM Industry

Bass, Berry & Sims PLC on

On August 18, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 23-05, finding that an entity’s proposal to facilitate referring surgeons’ ownership of turnkey...more

Paul Hastings LLP

Buyers Take Note: OIG Opinion Provides Insights on Physician-Owned Entities & Their Technologies

Paul Hastings LLP on

PART I- On April 20, 2022, the Office of Inspector General (“OIG”) of the Department of Health and Human Services (“HHS”) issued Advisory Opinion, No. 22-07 (“Opinion 22-07”), an informative opinion regarding arrangements...more

Saul Ewing Arnstein & Lehr LLP

OIG Maintains Position on "Carve Outs" of Federal Health Program Beneficiaries Implicating the Anti-Kickback Statute

Saul Ewing Arnstein & Lehr LLP on

A recent OIG Advisory Opinion concludes that a proposed arrangement, in which a commercial laboratory would contract with medical practices to assist them in developing their own clinical laboratories, necessarily implicates...more

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