News & Analysis as of

Sanctions Office of the Inspector General

Harris Beach PLLC

OIG Kickback Opinion: Referring Labs Providing Technical Component Services Implicate Anti-Kickback Statute

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This opinion addresses a proposed agreement (“Proposed Arrangement”) between a national anatomic pathology laboratory (“Requestor”) and laboratories owned in whole or in part by physicians who may refer (“Referring...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

Sheppard Mullin Richter & Hampton LLP

New OIG Opinion Permits Gift Cards to Beneficiaries in Limited Circumstances

On March 24, 2023, the Office of Inspector General (“OIG”) issued Advisory Opinion 23-03 (the “Opinion”), in which it decided not to impose sanctions on an Arrangement to provide prepaid gift cards to patients for certain...more

Robinson+Cole Health Law Diagnosis

Advisory Opinion 22-17: OIG Declines to Impose Sanctions on a Health System for Forgiveness of Credit Line Note Owed by Clinic

On September 6, 2022, the Office of Inspector General (OIG) published Advisory Opinion 22-17 (Advisory Opinion), in which it declined to impose sanctions against a regional 501(c)(3) not-for-profit health care system that...more

ArentFox Schiff

Investigations Newsletter: OIG Warns That Proposed Drug Discounts May Warrant Sanctions

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OIG Warns That Proposed Drug Discounts May Warrant Sanctions - On October 5, the US Department of Health and Human Services’ Office of Inspector General (OIG) issued an advisory opinion assessing a proposal that involved...more

Health Care Compliance Association (HCCA)

After a Retraction Demand Is Refused, What Then?

Report on Research Compliance 19, no.8 (August, 2022) - The most recent semiannual report (SAR) to Congress issued by the National Science Foundation (NSF) Office of Inspector General (OIG) details five misconduct...more

King & Spalding

OIG Declines to Impose Sanctions Against Device Manufacturer’s Medicare Cost-Sharing Subsidy in Clinical Trial

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On March 11, 2022, OIG issued Advisory Opinion No. 22-05 in which it responded to a request for an advisory opinion regarding a proposed subsidization of certain cost-sharing obligations in the context of a clinical trial...more

Arnall Golden Gregory LLP

OIG’s First Advisory Opinion of 2022 Allows for Expansion of Discount Programs

On January 19, 2022, the Department of Health and Human Services, Office of Inspector General (“OIG”) released a favorable advisory opinion, OIG Advisory Opinion No. 22-01 (the “Opinion”), analyzing a proposed expansion of...more

Health Care Compliance Association (HCCA)

After Investigation Finds ‘Mismanagement’ UT Austin Suspends PI, Repays NSF $1.3M

Report on Research Compliance 18, no. 10 (October, 2021) - A University of Texas at Austin principal investigator (PI) who, in the words of the National Science Foundation Office of Inspector General (OIG), “generally...more

Baker Donelson

OIG Approves Smartphone Loaner Program in Advisory Opinion 19-02

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The Office of Inspector General (OIG) approved in Advisory Opinion 19-02 a pharmaceutical manufacturer's proposal to implement a loaner program involving limited functionality smartphones containing technology that is...more

Holland & Knight LLP

OIG Issues Letter Declining to Impose Administrative Sanctions for Provision of Certain Free Drugs

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On Jan. 4, 2018, the HHS Office of Inspector General (OIG) issued an open letter containing guidance regarding the provision of certain free drugs to federal healthcare program beneficiaries. Specifically, the OIG stated that...more

Baker Donelson

OIG Approves Free Vaccine Refrigeration Systems in Physician Offices

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On September 16, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) released Advisory Opinion 16-09, approving a refrigerator manufacturer’s proposal to install a vaccine storage and...more

Mintz - Health Care Viewpoints

Billing Companies Beware – OIG Signals a Crackdown on Fraud and Abuse at All Levels

In an unprecedented administrative action, the U.S. Department of Health & Human Services Office of the Inspector General (“HHS-OIG”) penalized a medical billing company for preparing and submitting claims to Medicare for...more

Arnall Golden Gregory LLP

OIG Issues Advisory Opinion on Free Transportation

The Office of Inspector General (“OIG”) posted its most recent advisory opinion addressing a transportation program on October 21. This opinion analyzed a plan for a free van shuttle service provided by an integrated health...more

Cozen O'Connor

Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions - October 2015

Cozen O'Connor on

This edition of the Cozen O’Connor Aviation Regulatory Update reports on Congress’s six-month extension of FAA’s reauthorization; new U.S. Bilateral Aviation Safety Agreements with the European Union and Canada; the FAA’s...more

Baker Donelson

OIG Approves Home Health Provider's Free Introductory Visit Policy

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On August 6, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a for-profit home health provider’s policy to offer free introductory visits to...more

King & Spalding

OIG Issues Proposed Rules on Its Exclusion and CMP Authorities

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OIG has issued two proposed rules that would expand the agency’s ability to impose certain sanctions on entities and individuals involved with Federal health care programs. OIG’s first proposed rule—published in the Federal...more

King & Spalding

OIG: Cardiac Catheterization Arrangement Between Hospital and Physicians Not Subject to Sanctions

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On January 7, 2013, HHS OIG published a favorable advisory opinion on a management arrangement between a hospital and a cardiology group related to the provision of certain cardiac catheterization services at the hospital. ...more

Mintz - Health Care Viewpoints

OIG Approves Hospital’s Electronic Interface Arrangement

In OIG Advisory Opinion 12-20, the OIG determined that a proposed arrangement (the “Proposed Arrangement”) by a hospital (the “Requestor”) would not constitute grounds for the imposition of sanctions under the Anti-Kickback...more

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