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OIG Advisory Opinion 25-03: Navigating Anti-Kickback Rules and Safe Harbors in Telehealth Contractual Arrangements

On June 6, 2025, the Office of Inspector General (OIG) issued Advisory Opinion 25-03 (the “Opinion”), offering guidance for structuring telehealth collaborations in a manner that complies with the federal Anti-Kickback...more

California Prohibits PBM Discriminatory Practices Against 340B Program Covered Entities and Contract Pharmacies

The 340B Drug Program requires pharmaceutical manufacturers participating in the Medicaid program to provide covered outpatient drugs at significantly reduced prices to certain health care organizations and programs, referred...more

OIG Advisory Opinion 22-08 Permits Federally Qualified Health Center To Provide Smartphones to Patients to Promote Access to...

Telehealth—the provision and coordination of healthcare remotely by means of telecommunications technology—is now an essential tool in the delivery of health care services. The COVID-19 pandemic created an incentive for...more

OPA Program Update 2020 Highlights Changes to 340B Program Registration and Recertification Requirements

On July 20, 2020, the Health Resources and Services Administration's (HRSA) Office of Pharmacy Affairs (OPA) issued the OPA Program Update 2020. In addition to adopting new Covered Entity registration and recertification...more

CMS Revises and Updates Requirements for the Programs of All-Inclusive Care for the Elderly (PACE)

The Centers for Medicare & Medicaid Services (CMS) recently revised regulations (the "Regulations") for the Programs of All-Inclusive Care for the Elderly (PACE), making significant changes to ownership restrictions,...more

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