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OIG Reminds Us that Flat Fee Business Arrangements Aren’t Immune from AKS Scrutiny

On July 1, 2025, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 25-08, concluding that a medical device manufacturer’s proposed payment to access a...more

OIG Issues Favorable Advisory Opinion on Physician-Telehealth Arrangement

On June 11, 2025, the Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion No. 25-03 (Opinion), which provided favorable guidance for physician practices seeking to contract with...more

Event in Review: Private Equity Investment in Healthcare

Investment in the healthcare industry requires careful consideration, as it involves numerous distinct areas of the law. Venable's Private Equity Investment in Healthcare webinar series explores the unique issues and timely...more

OIG Provides Guidance on Physician Bonus Compensation

On October 13, 2023, the Department of Health and Human Services Office of Inspector General (the OIG) released an advisory opinion regarding a multi-specialty physician practice's (the Practice) proposed plan to pay bonuses...more

The Pandemic’s Effect on Physician Practice Transactions: Valuation Issues, Differing Buyer and Seller Expectations, and the Rise...

The transaction marketplace for physician practices is incredibly active for physician owners, transaction lawyers, financing sources, consultants, tax advisors, and many other stakeholders. Whether it’s health systems and...more

Eighth Circuit Curtails False Claims Act Liability Premised on Anti-Kickback Statute Violations

​​​​​​​Last week the Eighth Circuit Court of Appeals offered defendants in False Claims Act cases based on Anti-Kickback Statute (AKS) violations a significant new defense in its holding in United States ex rel. Cairns v....more

HHS 2021 Semiannual Report to Congress Draws Attention to Genetic Testing, Durable Medical Equipment, and Opioid Disorder...

On June 6, 2022, the U.S. Department of Health and Human Services (HHS), Office of Inspector General (OIG), released its spring 2022 semiannual report to Congress. The semiannual report covers the period of October 1, 2021 to...more

Contractual Safeguards That Fall Short of a Safe Harbor

According to a recent Advisory Opinion from the Department of Health and Human Services (HHS) Office of Inspector General (OIG), a proposed fee arrangement could run afoul of the Federal anti-kickback statute, 42 USC...more

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