In recent months, the Department of Health and Human Services, Office of Inspector General (“OIG” or “the agency”) announced two major developments in its effort to provide enhanced health care and life sciences industry...more
PART I-
On April 20, 2022, the Office of Inspector General (“OIG”) of the Department of Health and Human Services (“HHS”) issued Advisory Opinion, No. 22-07 (“Opinion 22-07”), an informative opinion regarding arrangements...more
8/30/2022
/ Anti-Kickback Statute ,
Beneficiaries ,
Business Ownership ,
Carve Out Provisions ,
Department of Health and Human Services (HHS) ,
Fraud Alerts ,
Irrevocable Trusts ,
Medical Devices ,
OIG ,
Ownership Interest ,
Physician Ownership
As it continues its focus not just on enforcement, but on compliance, members of the U.S. Department of Justice have foreshadowed a sea change for Chief Executive Officers and Chief Compliance Officers in corporate...more