Douglas A. Grimm, Gayland O. Hethcoat II, writing for ArentFox Schiff:
In Advisory Opinion No. 23-04, the US Department of Health and Human Services (HHS) Office of Inspector General (OIG) analyzed certain proposed changes to the functionality of a health care technology company’s online provider marketplace. As in an earlier 2019 opinion, OIG concluded that the company’s business model would not result in unlawful kickbacks and patient inducements.