In Advisory Opinion 20-03, published July 1, 2020, the Office of Inspector General (OIG) approved an arrangement in which a discount medical plan organization (DMPO) that receives annual membership fees from its members also...more
It appears that the Office of Inspector General (“OIG”) now has physicians squarely in the crosshairs of one of its most powerful enforcement tools: the Anti-Kickback Statute (“AKS”). The AKS is a criminal statute with...more
While the Department of Justice and the Department of Health and Human Services Office of Inspector General (OIG) have long scrutinized physician compensation arrangements, including medical director agreements, penalties...more
In OIG Advisory Opinion 14-06, the Office of Inspector General (OIG) concluded that payment by a specialty pharmacy to a retail pharmacy on a “per-fill” basis for services provided by the retail pharmacy could violate the...more
Advisory Opinion No. 14-06, issued August 15, addressed a plan by the chain to reimburse local pharmacies for referrals of patients in need of specialized drugs that the local pharmacies did not dispense. In the scenario...more
In its first Advisory Opinion of 2014, the Department of Health and Human Services Office of Inspector General (“OIG”) found that an arrangement between a placement agency (the “Placement Agency”) and certain senior...more