News & Analysis as of

Physicians Office of the Inspector General Civil Monetary Penalties

King & Spalding

OIG Issues Advisory Opinion Permitting Drug Manufacturer to Provide Travel, Lodging, and Expenses to Patients in Limited...

King & Spalding on

On January 15, 2020, OIG issued Advisory Opinion No. 20-02 analyzing an arrangement between a pharmaceutical manufacturer and certain drug recipients whereby the manufacturer provides certain drug recipients with financial...more

McDermott Will & Emery

Recent DOJ and OIG Actions Show Growing Federal Scrutiny of Physician Financial Arrangements

Over the last month the Office of Inspector General (OIG) of the Department of Health and Human Services and the Department of Justice (DOJ) have each taken actions that suggest an increasing appetite to examine the financial...more

McDermott Will & Emery

SGR Legislation Includes Gainsharing Fix and More Anti-Fraud Measures

McDermott Will & Emery on

The legislation repealing the Medicare sustainable growth rate formula (SGR), signed by President Obama on April 16, 2015, contained several anti-fraud related provisions that affect the health care industry. The provision...more

K&L Gates LLP

SGR Law Brings Changes to CMP Prohibition on Gainsharing

K&L Gates LLP on

On April 16, President Barack Obama signed into law the “Medicare Access and CHIP Reauthorization Act of 2015,” ending a perennial struggle over the Medicare reimbursement formula for physicians. Although the law is most...more

Benesch

OIG Announces Proposed AKS and CMP Regulations

Benesch on

On October 3, 2014, the Office of the Inspector General (“OIG”) issued a proposed rule codifying into regulation several statutory changes to the Antikickback Statute (“AKS”) and the Civil Monetary Penalty (“CMP”) Law. Nearly...more

Mintz

OIG Special Advisory Bulletin Provides Guidance on Application of Federal Anti-Kickback Statute to Pharmaceutical Manufacturer...

Mintz on

In recent years, copayment coupon programs have become standard promotional practices for both large and small pharmaceutical manufacturers. Copayment coupons are typically offered to commercially insured patients in order to...more

Epstein Becker & Green

OIG Proposes New Safe Harbors to the Anti-Kickback Statute and New Exceptions to the Two Civil Monetary Penalty Provisions

Epstein Becker & Green on

On October 3, 2014, the Department of Health and Human Services’ Office of Inspector General (“OIG”) published a proposed rule (“Proposed Rule”) to add new safe harbors to the federal health care program anti-kickback statute...more

K&L Gates LLP

Proposed Updates to the Civil Monetary Penalties Law for Health Care Providers

K&L Gates LLP on

On October 3, 2014, the Office of Inspector General of the Department of Health and Human Services (“OIG”) published a proposed rule and request for comments (“Proposed Rule”) that would amend certain rules under the Civil...more

Bradley Arant Boult Cummings LLP

OIG's Co-Management Arrangement for Cardiac Cath Labs

On January 7, 2013, the Department of Health and Human Services Office of Inspector General (“OIG”) posted a favorable advisory opinion concerning an existing co-management arrangement (“Arrangement”) between a large, rural,...more

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