News & Analysis as of

Inducements Office of the Inspector General

Holland & Hart LLP

Patient Inducements: Law and Limits

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Although often well-intentioned, offering free or discounted items or services to patients (e.g., gifts, rewards, writing off copays, free screening exams, free supplies, etc.) may violate federal and state laws governing...more

Rivkin Radler LLP

[Webinar] Lunch and Learn Series: Prohibitions on Provider Inducements - February 27th, 12:00 pm - 1:00 pm ET

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On Tuesday, February 27, the next installment of Rivkin Radler’s Healthcare Compliance Lunch & Learn series, will be presented by Rivkin Radler Partners, Geoffrey Kaiser and Benjamin Malerba. The program, “Prohibitions on...more

Harris Beach PLLC

Gift Cards For Medicare Patients Not Inducements, OIG Opines

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The Department of Health and Human Services’ Office of Inspector General (“OIG”) has offered an opinion on providing a gift card to certain Medicare Advantage plan enrollees who complete specific steps in an online patient...more

Akerman LLP - Health Law Rx

Healthcare Providers: Please Be Wary of Accepting Those Gifts!

There has been a longstanding and regrettable practice in the healthcare industry of pharmaceutical and medical device companies giving physicians gifts as illegal inducements. Concerned about this continued trend, the U.S....more

Baker Donelson

It's Déj Vu All Over Again as OIG Approves Yet Another Medigap/PHO Arrangement in Advisory Opinion 18-09

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With Advisory Opinion 18-09, the OIG continued its trend of approving arrangements between Medicare Supplemental Health Insurance (Medigap) insurers and preferred hospital network organizations (PHOs). As in prior advisory...more

Ruder Ware

Hospital Program for Free Support Services for Caregivers – Approved by OIG

Ruder Ware on

A recent Office of Inspector General (OIG) advisory opinion approved a proposal under which a hospital has established a caregiver center that provides or arranges for free or reduced-cost support services to caregivers in...more

Baker Donelson

OIG Allows Free and Reduced-Cost Services to Strained Caregivers in Advisory Opinion 18-05

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In what is becoming a steady trend, the Office of Inspector General (OIG) published another favorable opinion for an arrangement seeking to implement programs that support and engage family members who are increasingly...more

Baker Donelson

Nursing Facility Discounts Approved in OIG Advisory Opinion 17-08

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The OIG created an opening for nursing facility discounts to private payors when it approved a startup company's proposal to create a network of nursing facilities willing to offer discounts on the daily rates charged to...more

Arnall Golden Gregory LLP

Expanded Fraud and Abuse Liability under Proposed “Medicare for All” Bill

On September 13, 2017, Senator Bernie Sanders (I-VT) introduced his “Medicare for All Act of 2017” which, as the name implies, would expand Medicare to cover nearly every American. Although it is unlikely that the bill will...more

Baker Donelson

OIG Approves Free Lodging and Meals Under "Promotes Access to Care" Exception to Beneficiary Inducement CMP

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In Advisory Opinion 17-01, published March 10, 2017, the Department of Health and Human Services, Office of Inspector General (OIG) approved an academic medical center's proposal to provide free or reduced-cost lodging and...more

Mintz - Health Care Viewpoints

At Long Last, OIG Issues Final Rule for Beneficiary Inducement Safe Harbors

More than two years since issuing the proposed rule, the HHS Office of the Inspector General (OIG) issued the long-awaited and highly anticipated final rule (the Final Rule) that provides amendments to the Anti-Kickback...more

Baker Donelson

OIG Approves Charitable Program Providing Financial Assistance for MRIs in Advisory Opinion 15-14

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On November 13, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-14. The Arrangement at issue is a charitable program designed to assist financially needy...more

Baker Donelson

OIG Approves Another Patient Assistance Program in Advisory Opinion 15-16

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On December 28, 2015, the Office of Inspector General (OIG) approved another patient assistance program in Advisory Opinion 15-16. The OIG analyzed contributions to a private charitable organization under the anti-kickback...more

Baker Donelson

Charity's Patient Assistance Program Passes OIG Muster in Advisory Opinion 15-17

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On December 28, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued OIG Advisory Opinion 15-17, approving a charity’s proposal to unveil a new patient assistance program dedicated to...more

Baker Donelson

OIG Issues (Another) Favorable Advisory Opinion Regarding Medigap/Preferred Hospital Network Arrangement in Advisory Opinion 16-01

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On January 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 16-01, approving yet another insurer’s proposed contract with a preferred hospital network. The...more

King & Spalding

OIG Authorizes Arrangement to Pay for MRI Services

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On November 20, 2015, OIG issued a favorable advisory opinion, Advisory Opinion No. 15-14, regarding a charitable organization’s arrangement to pay for magnetic resonance imaging (MRI) services for patients afflicted with a...more

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