From Health Law Diagnosis, by Nathaniel Arden & Michael Lisitano: On October 13, 2023, the Office of Inspector General (OIG) published Advisory Opinion 23-07, in which the OIG issued a favorable opinion regarding a physician group employer’s proposal to pay bonuses to its employed physicians based on net profits derived from certain procedures performed by […]
Tag: OIG Advisory Opinion
From Bass, Berry & Sims, by Jennifer E. Michael & Danielle M. Sloane: The U.S. Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion 23-06, wherein the OIG reiterated its longstanding position that carving out federal health care program (FHCP) business from an arrangement does not insulate the arrangement from […]