Matthew Babcock on Advisory Opinions

OIG Approves Discounts on Inpatient Deductibles

The Office of Inspector General (OIG) recently issued a new favorable OIG Advisory Opinion, concluding that, although the proposed arrangement (“Proposed Arrangement”) between a Medicare Supplement insurer (“MediGap Plan”)...more

3/11/2024 / Advisory Opinions , Anti-Kickback Statute , Beneficiary Inducement , Civil Monetary Penalty , Deductibles , Inpatient Billing , Medicare Part A , Medigap , OIG

OIG’s Favorable Advisory Opinion: Physician Consulting Firm’s Gift Cards to its Clients for Referring New Physician Practices

This favorable OIG opinion relates to Requestor who provides consulting services to physician practices and the Requestor’s proposed arrangement (“Proposed Arrangement”) to offer its current physician practice customers...more

1/18/2024 / Advisory Opinions , Anti-Kickback Statute , Healthcare , Healthcare Reform , MIPS , OIG , Proposed Regulation

OIG Opinion: DME Supplier Subsidy of Medicare Cost-Sharing in Cardiac Trial OK

This favorable OIG opinion concludes that although the proposed arrangement (“Proposed Arrangement”) to subsidize Medicare cost-sharing obligations for Medicare patients in a cardiac clinical trial (“Study”) would constitute...more

1/4/2024 / Advisory Opinions , Anti-Kickback Statute , Civil Monetary Penalty , Department of Health and Human Services (HHS) , Food and Drug Administration (FDA) , Medicare , OIG

Cochlear Implant Manufacturer Proposes to Provide Free Compatible Hearing Aids

This opinion addresses a proposed arrangement (“Proposed Arrangement”) by the manufacturer of cochlear implants (“Requestor”), where the Requestor would provide certain patients who receive one of their implants with a free...more

11/2/2023 / Advisory Opinions , Anti-Kickback Statute , Civil Monetary Penalty , Health Care Providers , Manufacturers , Medical Devices , OIG , Remuneration

OIG’s Favorable Opinion: Employed Physicians Paid Bonuses Based on ASCs’ Net Profits

This opinion addresses a proposed arrangement (“Proposed Arrangement”) between a multi-specialty physician practice (“Requestor”) that employs approximately 11 physician employees (“Physician Employees”). In addition to base...more

10/19/2023 / Advisory Opinions , Ambulatory Surgery Centers , Anti-Kickback Statute , Bonuses , Fraud and Abuse , Medicaid , Medicare , Net Profits , OIG , Physicians

Opinion on Possible Kickbacks Between Health System and Clinic

This opinion regards a proposed restructuring of financial relationships, which includes the forgiveness of debt, between a health system and a nearby clinic. ...more

9/14/2022 / Advisory Opinions , Anti-Kickback Statute , Debt Forgiveness , FQHC , HRSA , Kickbacks , OIG , PHSA , Safe Harbors

OIG Decides Not to Impose Sanctions on Medical-Equipment Manufacturer in Financial Arrangement

Department of Health and Human Services Office of Inspector General (“OIG”) Advisory Opinion 22-13 Issued: June 23, 2022 This opinion addresses a durable medical equipment (“DME”) manufacturer’s arrangements with...more

6/28/2022 / Advisory Opinions , Anti-Kickback Statute , Department of Health and Human Services (HHS) , Durable Medical Equipment , Federal Health Care Programs (FHCP) , Financial Institutions , Financing , Manufacturers , OIG

Matthew Babcock

Harris Beach PLLC

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