Search results for: advisory opinion
OIG Advisory Opinion Okays Treatment-based Patient Incentives
A digital health company that uses smartphone and smart debit card technology to operate an incentive program for patients with substance use disorders was given a favorable advisory opinion by the Office of Inspector General for the Department of Health and Human Services (OIG) to provide patient incentives in the form of a debit card…
Read MoreOIG Advisory Opinion Finds Proposed Joint Venture Riddled with Problems
A contract therapy services company that provides management of day-to-day operations and therapy staffing for rehabilitation programs in long-term care communities (i.e., skilled nursing facilities, assisted living facilities, and full-service continuing care retirement communities) recently was advised by the HHS Office of Inspector General that a proposed joint venture arrangement presented a host of concerns…
Read MoreOIG Issues Four Advisory Opinions in December
The U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) cranked out four Advisory Opinions in the waning days of 2020. On December 18, the watchdog agency gave its blessing to a management company that wants to provide Medicaid enrollment application assistance services to certain individuals and affiliated SNFs and an…
Read MoreOIG Offers Advisory Opinions on COVID-19-Related Arrangements, But …
The COVID-19 pandemic has resulted in a unique set of circumstances for many healthcare providers. Delivering quality patient care, while at the same time trying to navigate existing laws and regulations, has many providers questioning whether the arrangements they are making in response to this public health emergency will not get them into trouble with…
Read MoreOIG Issues Advisory Opinion on Hospital Training Facility
On January 13, the Office of Inspector General (OIG) posted an advisory opinion in which it approved a hospital’s request to provide discounted training to a fire department’s personnel at the hospital’s facility. The hospital asked the government watchdog whether such an arrangement would constitute grounds for the imposition of sanctions under the exclusion authority…
Read MoreAdvisory Opinion: Clinic Can Provide Free Telemedicine Equipment, Services
A nonprofit, federally qualified health center look-alike (FQHC) can use grant funds to provide telehealth equipment and services for free to facilitate encounters with patients of a county-run clinic that provides testing, treatment and counseling for HIV, based on a recent advisory opinion issued by the Department of Health and Human Services Office of the…
Read MoreOIG Revokes Advisory Opinion on Patient-assistance Charity
In what is being called a first-of-its-kind move, the Office of Inspector General for the U.S. Department of Health and Human Services late last month revoked an advisory opinion it issued, and later modified, relating to a patient-assistance charity. In its opinion, the OIG said it made its determination to revoke its original opinion “based…
Read MoreOIG Opinion: Drug Maker Can Provide Free Medication
On March 23, the Department of Health and Human Services Office of the Inspector General issued a favorable ruling to a drug manufacturer looking to provide a free medication to patients in need of a one-time treatment made from their own cells. The drug maker (Requestor) makes the FDA-approved drug for two indications that is…
Read MoreOIG Opinion: Providing Sample Ostomy Products Does not Violate Anti-Kickback Statute
An ostomy product distributor can give free samples to Medicare patients without worrying about violating the federal Anti-Kickback Statute, according to a recent advisory opinion from the Office of Inspector General for the U.S. Department of Health and Human Services. The Anti-Kickback Statute makes it a criminal offense to knowingly and willfully offer, pay, solicit…
Read MoreOIG Opinion Applies Access to Care Exception
Can a hospital system provide free or reduced-cost lodging and meals to certain financially needy patients, or would such an arrangement (a) constitute either a violation of the federal anti-kickback statute or (b) constitute grounds for the imposition of civil monetary penalties because it would violate a provision of the Social Security Act that prohibits…
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