On June 20, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 25-04, in which it declined to approve a proposal by a medical device company (Requestor) to pay the...more
On June 11, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 25-03, approving a proposal by a management services organization (MSO) and its friendly PC...more
6/25/2025
/ Advisory Opinions ,
Anti-Kickback Statute ,
Contract Terms ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Health Insurance ,
Healthcare Fraud ,
Medicaid ,
Medicare Advantage ,
OIG ,
Patient Access ,
Proposed Rules ,
Safe Harbors ,
Telehealth
In 2024, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) provided useful insights to the healthcare industry regarding how it approaches various fraud and abuse issues in an...more
2/7/2025
/ Anti-Kickback Statute ,
Billing ,
Compliance ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Healthcare ,
Healthcare Fraud ,
Medicare ,
Medicare Advantage ,
OIG ,
Risk Management ,
Settlement ,
Stark Law ,
Telehealth
On December 11, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a Special Fraud Alert (SFA) on what it refers to as “suspect” marketing schemes involving “questionable payments and...more
On September 13, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 24-08, in which it declined to approve a proposal by a Medicare Advantage organization (MAO)...more
9/19/2024
/ Advisory Opinions ,
Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Employer Group Health Plans ,
Health Insurance ,
Healthcare ,
Medicare ,
Medicare Advantage Organizations (MAOs) ,
OIG ,
Shared Savings Program
On June 17, the U.S. Department of Health and Human Services Office of Inspector General (OIG) posted Advisory Opinion 24-03, approving an arrangement under which a pharmaceutical manufacturer provides travel, lodging, and...more
6/28/2024
/ Advisory Opinions ,
Anti-Kickback Statute ,
Fraud and Abuse ,
Health Insurance ,
Healthcare ,
Life Sciences ,
Medicaid ,
Medicare ,
OIG ,
Pharmaceutical Industry ,
Prescription Drugs
We are pleased to bring you our 12th annual Healthcare Fraud & Abuse Review. Our Review provides comprehensive coverage of the most significant civil and criminal enforcement issues facing healthcare providers. Each year, we...more
2/27/2024
/ Anti-Kickback Statute ,
CARES Act ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare ,
Healthcare Fraud ,
Kickbacks ,
Medical Devices ,
Pharmaceutical Industry ,
Physicians ,
Prescription Drugs ,
Qui Tam ,
Settlement ,
Stark Law ,
Telemedicine
The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) is tasked with providing objective oversight to protect the integrity and promote the efficiency of Medicare, Medicaid, and more than...more
2/1/2024
/ Advisory Opinions ,
Anti-Kickback Statute ,
Civil Monetary Penalty ,
Department of Health and Human Services (HHS) ,
Enforcement Actions ,
Health Information Technologies ,
Healthcare ,
Healthcare Fraud ,
Healthcare Reform ,
Information Blocking Rules ,
Litigation Strategies ,
New Guidance ,
OIG ,
Regulatory Agenda ,
Telehealth
On January 3, the U.S. Department of Health and Human Services Office of Inspector General (OIG) posted Advisory Opinion 23-15, approving a physician practice consultant’s proposal to offer gift cards to its customers when...more
On September 25, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion 23-06, in which it declined to approve an anatomic pathology laboratory’s proposal to purchase...more
The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued Advisory Opinion 23-03, approving a proposal by the manufacturer of a colorectal cancer screening test and its wholly owned...more
On March 23, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) announced a new, expanded frequently asked questions (FAQs) process. Although OIG has long maintained FAQs on...more
The Office of Inspector General (OIG) for the U.S. Department of Health and Human Services recently posted Advisory Opinion 22-20, approving an acute care hospital’s arrangement under which its employed nurse practitioners...more
1/6/2023
/ Acute Facilities ,
Advisory Opinions ,
Anti-Kickback Statute ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Hospitals ,
Nurse Practitioners ,
OIG ,
Physicians ,
Remuneration ,
Stark Law
On October 5, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services published Advisory Opinion No. 22-19, finding that a proposal by an entity funded entirely by manufacturers of oncology...more
10/12/2022
/ Advisory Opinions ,
Anti-Kickback Statute ,
Appeals ,
C-Corporation ,
Cost-Sharing ,
Federal Poverty Line ,
Fraud and Abuse ,
Generic Drugs ,
Inflation Reduction Act (IRA) ,
Medicare Part D ,
OIG ,
Patient Assistance Programs
On July 25, the U.S. Court of Appeals for the Second Circuit affirmed the U.S. District Court for the Southern District of New York (SDNY) decision granting summary judgment in favor of the Department of Health Human Services...more
7/29/2022
/ Advisory Opinions ,
Anti-Kickback Statute ,
Appeals ,
Department of Health and Human Services (HHS) ,
False Claims Act (FCA) ,
New York ,
OIG ,
Pfizer ,
Pharmaceutical Industry ,
Prescription Drugs ,
Summary Judgment
On June 29, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services published Advisory Opinion 22-14, approving in part, and denying in part, a request from an ophthalmology practice...more
On June 23, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services published Advisory Opinion 22-13, approving an arrangement under which a durable medical equipment (DME) manufacturer...more
6/28/2022
/ Advisory Opinions ,
Anti-Kickback Statute ,
Beneficiaries ,
Customers ,
Department of Health and Human Services (HHS) ,
Financial Institutions ,
Health Care Providers ,
Lenders ,
Manufacturers ,
Medical Supplies ,
OIG ,
Patients
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