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OIG Issues Advisory Opinion Re: Municipal Payment for Medical Transportation Services

The OIG has issued an Advisory Opinion regarding a municipality’s use of tax revenues for payment of a stipend to a volunteer ambulance squad to cover the cost of co-payments and deductibles that would otherwise be incurred by residents, as well as the cost of transports provided to residents without insurance coverage.  In Advisory Opinion […]

OIG Proposes New Safe Harbors and Other Regulatory Changes

The HHS Office of Inspector General has published notice of a proposed rule which (if adopted) would modify some of the existing safe harbors to the anti-kickback statue, and add new safe harbors (including a long-awaited safe harbor for free or discounted local transportation services).  The proposed rule would also codify civil monetary provisions for […]

OIG Issues Unfavorable Advisory Opinion to Specialty Pharmacy For Support Service Payments

On August 15, 2014, the OIG issued an unfavorable Advisory Opinion to a specialty pharmacy in connection with the pharmacy’s proposal to pay local retail pharmacies for support services that they provide in connection with patient referrals to the specialty pharmacy.  The specialty pharmacy dispensed specialty pharmaceuticals that are often unavailable to retail pharmacies.  Under […]

OIG Issues Special Fraud Alert Concerning Laboratory Payments to Referring Physicians

Earlier today, the OIG issued a Special Fraud Alert concerning laboratory payments to referring physicians.  The OIG identified 2 different types of payment arrangements that may be viewed as problematic under the Anti-Kickback law: blood specimen collection, processing and packaging arrangements and registry payments. The OIG described specimen processing arrangements as payments from laboratories to […]

Corporate Integrity Agreement Gone Wrong: OIG Excludes Entity Found Non-Compliant with CIA

On April 3rd, the OIG issued a press release announcing that it was excluding CSHM, LLC (“CSHM”), a pediatric dental management chain, from participation in the Medicare and Medicaid programs for a period of five years.  CSHM operates a national chain of pediatric dental facilities known as Small Smiles Dental Centers, which primarily serves Medicaid […]

OIG Publishes Op-Ed Suggesting Mandatory Random Drug Testing For Health Care Professionals

In an Op Ed article published in yesterday’s New York Times (, HHS OIG Daniel Levinson has called for mandatory random drug testing by hospitals for all health care workers with access to drugs.  Citing recent cases involving drug diversions by health care workers that led to patient harm, the OIG indicated that since transportation […]


On the eve of the New Year, the Office of Inspector General (“OIG”) issued Advisory Opinion 12-22, which reviewed a cardiac catheterization co-management agreement between a hospital and a cardiology group.  The Advisory Opinion is notable for its detail, and may be instructive for hospitals and physician practices wishing to establish similar arrangements. The hospital […]

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