medical

By Deborah J. Juneau

On June 9, 2015, the OIG issued a new Fraud Alert, cautioning physicians who enter into compensation arrangements such as medical directorships to ensure that the arrangements reflect fair market value for bona fide services that the physicians actually provide. The OIG reiterated that a compensation arrangement could violate the Anti-kickback

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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