OIG Advisory Opinion No. 13-10

On August 9, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued a favorable Advisory Opinion, 13-10 [PDF], concerning an arrangement whereby a vendor (Vendor) that is a subsidiary of a pharmaceutical manufacturer would enter into service arrangements with hospitals to provide patients with certain diagnoses services after hospital discharge in order to reduce hospital readmissions (Proposed Arrangement). OIG examined the arrangement under both the Anti-Kickback Statute and the civil money penalty (CMP) provision prohibiting inducements to beneficiaries and determined that it would not impose sanctions under either provision based on the specific facts presented.

To read the full Opinion:

http://oig.hhs.gov/fraud/docs/advisoryopinions/2013/AdvOpn13-10.pdf