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Federal Health Care Programs (FHCP) Incentives

King & Spalding

OIG Issues Favorable Opinion Regarding a Program to Provide Patients with Free Access to a Pharmaceutical Product

King & Spalding on

On January 10, 2025, OIG posted a favorable advisory opinion approving a proposed program (Program) to provide patients who meet certain financial need criteria with free access to a pharmaceutical product that has limited...more

Rivkin Radler LLP

Health Network Pays $345 Million for Compensating Physicians Above FMV

Rivkin Radler LLP on

Community Health Network, Inc., based in Indianapolis, Indiana, has paid $345 million to settle alleged violations of the False Claims Act (FCA). The lawsuit was initiated through a whistleblower complaint that was filed in...more

Mintz - Health Care Viewpoints

Key Takeaways from the OIG’s New Comprehensive General Compliance Program Guidance

The Department of Health and Human Services’ Office of Inspector General (OIG) published a General Compliance Program Guidance (GCPG) on November 6, 2023, marking the first update to OIG’s compliance program guidance...more

Proskauer - Health Care Law Brief

OIG Approves Cash Equivalents Paid to Patients Participating in Contingency Management Program Offered Through Digital Health...

Contingency management (CM) is a form of intervention treatment program that incentivizes patients with substance use disorders to observe certain conditions—such as non-use of drugs or alcohol confirmed via urine drug...more

Baker Donelson

OIG Advisory Opinion 18-11 Offers Rare Insight to Safe Harbor for Price Reductions Offered to Eligible Managed Care Organizations

Baker Donelson on

The Office of Inspector General (OIG) confirmed in Advisory Opinion No. 18-11 that the safe harbor for Price Reductions Offered to Managed Care Organizations applies to "any remuneration," not just price reductions or...more

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