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Office of the Inspector General Anti-Kickback Statute Preferred Hospital Networks Arrangement

Arnall Golden Gregory LLP

OIG Approves Arrangement Incentivizing Medigap Policyholders to Seek Treatment From PHO Network Hospitals

The Department of Health and Human Services, Office of Inspector General (“OIG”) recently released a favorable advisory opinion, OIG Advisory Opinion No. 24-01 (the “Opinion”), to a Medicare Supplemental Health Insurance...more

King & Spalding

OIG Issues Additional Favorable Advisory Opinion Regarding Medigap Plan and Preferred Hospital Organization Arrangement

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On July 7, 2021, OIG posted Advisory Opinion No. 21-07 relating to a proposed arrangement between a Medigap Plan and a Preferred Hospital Organization (PHO). The proposed arrangement involves (i) a discount on policyholder’s...more

King & Spalding

OIG Issues Favorable Advisory Opinions Regarding Medigap Plan and Preferred Hospital Organization Arrangements

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Last week, OIG posted Advisory Opinions Nos. 21-03, 21-04, and 21-05 relating to three near-identical arrangements between Medigap plans and Preferred Hospital Organizations (PHOs). The arrangements involve (i) a discount on...more

Baker Donelson

It's Déj Vu All Over Again as OIG Approves Yet Another Medigap/PHO Arrangement in Advisory Opinion 18-09

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With Advisory Opinion 18-09, the OIG continued its trend of approving arrangements between Medicare Supplemental Health Insurance (Medigap) insurers and preferred hospital network organizations (PHOs). As in prior advisory...more

Baker Donelson

OIG Approves (Again) Another Medigap/PHO Arrangement in Advisory Opinion 18-06

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With Advisory Opinion 18-06, issued July 11, 2018, the OIG added to the ever-growing number of favorable advisory opinions addressing an agreement between a Medicare Supplemental Health Insurance (Medigap) insurer and a...more

Baker Donelson

OIG Advisory Opinion 18-04: Another Favorable Medigap/PHO Arrangement

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On June 7, 2018, the OIG issued favorable Advisory Opinion 18-04, thereby approving another arrangement between a group of Medicare Supplemental Health Insurance (Medigap) insurers and a preferred hospital organization (PHO)....more

Baker Donelson

OIG Advisory Opinion 17-06: Another Medigap/PHO Arrangement Approved

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Advisory Opinion 17-06 joins a long list of opinions approving arrangements between a Medicare Supplemental Health Insurance (Medigap) insurer and a preferred hospital organization (PHO). While this advisory opinion does not...more

Baker Donelson

OIG Approves Another Medigap/Preferred Hospital Network Arrangement in Advisory Opinion 16-11

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On November 3, 2016, the OIG issued another favorable Advisory Opinion, No. 16–11, regarding an agreement between a Medigap insurer and preferred hospital network. The OIG has issued several opinions regarding similar...more

Baker Donelson

Another Medigap/Preferred Hospital Network Arrangement Approved by OIG in Advisory Opinion 16-05

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On May 3, 2016, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued another favorable advisory opinion, No. 16-05 [PDF], regarding an agreement between a Medicare Supplemental Health...more

Baker Donelson

OIG Approves Another Medigap/Preferred Hospital Network in Advisory Opinion 16-04

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On April 18th, the OIG issued a new favorable Advisory Opinion, No. 16–04, regarding an agreement between a Medigap insurer and preferred hospital network. The opinion tracked other, similar opinions in favorably addressing...more

Baker Donelson

Yet Again, OIG Approves Medigap Policy Contracts with Preferred Hospital Network

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On March 11, 2016, the U.S. Department of Health & Human Service, Office of the Inspector General (OIG) issued an advisory opinion approving the use of a preferred hospital network as part of Medicare Supplemental Health...more

Baker Donelson

OIG Issues (Another) Favorable Advisory Opinion Regarding Medigap/Preferred Hospital Network Arrangement in Advisory Opinion 16-01

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On January 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 16-01, approving yet another insurer’s proposed contract with a preferred hospital network. The...more

Baker Donelson

Again, the OIG Approves a Medigap Policy Contract with Preferred Hospital Networks

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On June 12, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-08. This opinion continues the well-established pattern of favorable advisory opinions which...more

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