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By Deborah J. Juneau

The OIG issued Advisory Opinion 15-3 to address an arrangement proposed by a licensed offeror of Medicare Supplemental Health Insurance (“Medigap”) policies (the “Requestor”), in which the Requestor would indirectly contract with a preferred hospital organization (“PPO”) having contracts with a national network of hospitals (the “Network Hospitals”) for discounts on

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By Lyn S. Savoie

The latest OIG Advisory Opinion, issued February 9, 2015, addresses the issue of sharing federal health care program payments with an excluded practitioner.   While federal statutes prohibit payment by any federal health care program, including Medicare or Medicaid, for items or services furnished by an excluded person or furnished at the