OIG periodically makes updates to its Integrity Agreement (IA) and Corporate Integrity Agreement (CIA) model language. It is important for healthcare organizations – even those not subject to a CIA – to monitor changes to...more
On September 15, 2021, OIG posted Advisory Opinion 21-12, regarding a proposed arrangement involving a program to offer certain free items and services to patients who experience specific complications after undergoing...more
On July 7, 2021, OIG posted Advisory Opinion No. 21-07 relating to a proposed arrangement between a Medigap Plan and a Preferred Hospital Organization (PHO). The proposed arrangement involves (i) a discount on policyholder’s...more
Last week, OIG posted Advisory Opinions Nos. 21-03, 21-04, and 21-05 relating to three near-identical arrangements between Medigap plans and Preferred Hospital Organizations (PHOs). The arrangements involve (i) a discount on...more
On August 24, 2020, CMS released a notice extending its timeline to publish its final rule with significant changes to the Stark regulations that was proposed in October 2019. Previously, CMS had indicated that it intended...more
On July 1, 2020, OIG published an advisory opinion regarding a discount medical plan organization (DMPO). A DMPO is not an insurer but contracts with providers who agree to reduce their fees for the DMPO’s members. Under...more
On December 29, 2017, OIG issued a favorable advisory opinion interpreting the application of the gainsharing civil monetary penalty provision (Gainsharing CMP) and the Anti-Kickback Statute in connection with a proposed...more
On April 18, 2017, the United States District Court for the Middle District of Florida adopted the magistrate judge’s report and recommendation and granted BayCare Health System’s (BayCare’s) motion for summary judgment. The...more