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OIG OKs Physician Consultant Gift Card Arrangement

On January 3, 2024, the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) published OIG Advisory Opinion No. 23-15 (the “Opinion”), which addresses a request from a consulting company (the...more

The Value Based Enterprise Safe Harbors and Exceptions

In recognition that the prior versions of the Stark Law and Anti-Kickback Statute (AKS) rules were not designed for a value-based health care delivery system, the new value-based safe harbors and exceptions (released in late...more

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