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OIG Approves Consultant’s Provision of Gift Cards to Physician Practices

The US Department of Health and Human Services Office of Inspector General (OIG) published favorable Advisory Opinion No. 23-15 on January 3, which concluded that a consultant’s proposal to provide gift cards to existing...more

OIG Approves Net Profit–Based Bonuses for Employed Physicians

The US Department of Health and Human Services Office of Inspector General (OIG) recently released Advisory Opinion No. 23-07, in which OIG approved a proposed arrangement to pay employed physicians bonuses based on net...more

OIG Rejects the Formation and Operation of Surgeon-Owned IONM Businesses

The US Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently evaluated the risks associated with certain intraoperative neuromonitoring (IONM) services arrangements in its release of...more

End of the PHE: Preparing for Return to Normal for Stark Law and Anti-Kickback Statute

Concurrent with the termination of the COVID-19 Public Health Emergency, various regulatory flexibilities will also come to an end, including the blanket waivers to the Stark Law and related enforcement discretion under the...more

HHS Regulatory Sprint Crosses the Finish Line: New Stark and Anti-Kickback Rules Forecast Big Changes for Patients and Value-Based...

Powerfully illustrating the efforts of the US Department of Health and Human Services (HHS) to transform the US healthcare system to a value-based model, the Office of the Inspector General (OIG) and the Centers for Medicare...more

CMS and OIG Offer Additional Details on Blanket Waivers and AKS Policy Statement

The Centers for Medicare & Medicaid Services and the US Department of Health and Human Services Office of Inspector General have provided additional guidance and clarification on the application of Stark Law blanket waivers...more

OIG and CMS Coordinate Seismic Change to Fraud and Abuse Laws—What It Means for the Health Industry

Highlighting the US Department of Health and Human Services’ (HHS) efforts to transform the US healthcare system to a value-based model, the Office of the Inspector General (OIG) and the Centers for Medicare and Medicaid...more

Retail Pharmacy: OIG Signals It’s Okay to Reward Again

OIG Advisory Opinion paves the way for expanded retailer reward programs. The US Department of Health and Human Services Office of Inspector General (OIG) issued an advisory opinion on September 7 that provides important...more

The OIG Work Plan: Does OIG Always Know Best?

Provider Compliance Departments routinely set audit priorities based, in part, on OIG’s Work Plan, but what should a provider do if it disagrees with a position that the OIG takes? Providers should be prepared to defend their...more

HHS OIG Issues Revised Self-Disclosure Protocol

OIG touts substantial benefits of disclosing, provides greater detail for different types of disclosures, and captures 15 years of OIG Self-Disclosure Protocol experience....more

Protections to Be Extended for Electronic Health Record Donations

CMS and OIG issue similar proposed rules to modify the electronic health record exception and safe harbor. On April 10, the Centers for Medicare & Medicaid Services (CMS) and the Office of Inspector General (OIG) of...more

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