A common question in the context of Medicare Advantage (“MA”) distribution and compensation is how agents and brokers may be compensated for commissions and administrative payments and whether, and to what extent, referral...more
On March 2, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services published Advisory Opinion 22-04, approving a program under which the requestor provides digital contingency management...more
In an uncertain health care environment following the presidential election, the Department of Health & Human Services Office of Inspector General (“OIG”) finalized a new rule expanding existing safe harbors to the federal...more