Healthcare Regulatory Check-up | March 2023

This issue of McDermott’s Healthcare Regulatory Check-Up highlights significant regulatory activity for March 2023. We discuss several criminal and civil enforcement actions that involve Anti-Kickback Statute (AKS) and beneficiary inducement issues. We also highlight the recent Office of Inspector General (OIG) advisory opinions 23-03, as well as other notable developments, including OIG’s creation of a new FAQ process and revised CMS Self-Referral Disclosure Protocol forms.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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