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Office of the Inspector General Joint Venture

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - May 9th - 10th, New York, NY

Hosted by the American Conference Institute, the 19th Annual FCPA & Anti-Corruption Conference for the Life Sciences Industry returns for another exciting year with carefully researched programming based on critical findings...more

Robinson+Cole Health Law Diagnosis

Advisory Opinion 23-05: OIG Warns Sanctions Would Likely be Issued in Response to Certain Proposed Contractual Joint Venture

On August 18, 2023, the Office of Inspector General (OIG) published Advisory Opinion 23-05 (Advisory Opinion), in which the OIG warned that it would likely issue sanctions under the Federal anti-kickback statute (AKS) if a...more

Robinson & Cole LLP

Health Law Diagnosis - Advisory Opinion 23-05: OIG Warns Sanctions Would Likely be Issued in Response to Certain Proposed...

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On August 18, 2023, the Office of Inspector General (OIG) published Advisory Opinion 23-05 (Advisory Opinion), in which the OIG warned that it would likely issue sanctions under the Federal anti-kickback statute (AKS) if a...more

Bass, Berry & Sims PLC

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

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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

Saul Ewing LLP

OIG Issues Unfavorable Advisory Opinion for Proposed IONM Joint Venture

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The HHS Office of Inspector General issued an 'unfavorable' advisory opinion in August with respect to a proposed joint venture relating to interoperative neuro monitoring. Parties considering joint ventures and those in...more

Stevens & Lee

OIG Says Proposed Surgery Monitoring Arrangement May Violate Kickback Statute

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On August 18, the Office of Inspector General in the Department of Health and Human Services (“OIG”) issued Advisory Opinion 23-05 in which it concluded that a proposed arrangement involving the formation of a company...more

Akin Gump Strauss Hauer & Feld LLP

OIG Joint Venture Advisory Opinion Does Not Consider Multiple Court Decisions That Undermine the Conclusions in its Opinion

 Key Points - HHS-OIG recently issued an Advisory Opinion finding that proposed JV, if undertaken, could constitute prohibited remuneration under the AKS. The scope of material the OIG may consider is limited. The OIG...more

Mintz - Health Care Viewpoints

OIG Reiterates its Longstanding Concern about Joint Ventures between Health Care Providers/Suppliers and Referral Sources

On November 22, 2021, the Office of Inspector General for the Department of Health and Human Services (OIG) posted a negative Advisory Opinion regarding a proposed joint venture (JV) for the provision of therapy services...more

Epstein Becker & Green

OIG Issues Favorable Advisory Opinion on Ambulatory Surgery Center Joint Venture

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The U.S. Department of Health and Human Services’ Office of Inspector General (“OIG”) recently issued Advisory Opinion No. 21-02, regarding a joint investment by a health system, a manager, and certain surgeons in an...more

McGuireWoods LLP

OIG Advisory Opinion Allows ASC Joint Venture by Management Company and Hospital-Employed Physicians

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On April 29, 2021, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a favorable advisory opinion regarding the development and investment of an ambulatory surgery center (ASC) owned...more

Saul Ewing LLP

OIG Issues Favorable Advisory Opinion For Hospital/Physician ASC Joint Venture

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In a recent advisory opinion, the Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services (“HHS”) concluded that an investment by a health system, a management company, and surgeons in an...more

BakerHostetler

New Favorable OIG Advisory Opinion – ASC Joint Ventures

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On April 26, 2021, the Office of the Inspector General (OIG) of the Department of Health & Human Services (HHS) released Advisory Opinion No. 21-02 (Opinion 21-02), a favorable opinion regarding an ambulatory surgery center...more

Rivkin Radler LLP

OIG Issues Favorable Advisory Opinion On Hospital/Physician Joint Venture ASC

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In a recent advisory opinion, the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) concluded that certain investments by a health system, manager and physicians in an ambulatory surgery center...more

Bass, Berry & Sims PLC

First Small Business Administration OIG Review of the All Small Mentor-Protégé Program Finds Areas for Improvement

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In 2016, the Small Business Administration (SBA) established a new government wide mentor-protégé program for small businesses called the All Small Mentor-Protégé Program (ASMPP). The purpose of the program was for...more

PilieroMazza PLLC

Weekly Update Newsletter - April 2019 #3

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GOVERNMENT CONTRACTING - As reported by Bloomberg Government, the Department of Health and Human Services is competing for a follow-on contract worth as much as $347 million to continue implementing the federal employee...more

PilieroMazza PLLC

Weekly Update Newsletter - February 2019 #4

PilieroMazza PLLC on

GOVERNMENT CONTRACTING - The Government Accountability Office (GAO) sustained a protest filed by Ekagra Partners, LLC challenging the terms of a request for proposal (RFP) issued by the General Services Administration...more

Foley & Lardner LLP

The Resurgence of the Ambulatory Surgery Center: Seven Considerations for Ownership

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After a prolonged period of stagnant growth primarily due to a glut of capacity coupled with flat or declining revenue growth, we’re beginning to see a resurgence of Ambulatory Surgery Centers (ASCs). In fact, experts are...more

Proskauer Rose LLP

OIG Issues Special Fraud Alert on Business Arrangements with Physician-Owned Entities

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On March 26, the HHS Office of Inspector General (OIG) issued a Special Fraud Alert (Fraud Alert) reiterating its long-standing concern that the opportunity for a referring physician to earn a profit by investing in a venture...more

Baker Donelson

OIG Calls PODs "Inherently Suspect"

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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

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