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Civil Monetary Penalties

Have a Plan for Planned Giving: Funds Being Donated Not a Factor in Fraud and Abuse Analysis

[02/25/22]

Posted on February 25, 2022 in Health Law News

Published by: Hall Render

On February 4, 2022, the Department of Health & Human Services Office of Inspector General (“OIG”) issued Advisory Opinion 22-02 protecting a children’s hospital’s donor-funded charity program (“Proposed Arrangement”). Under the Proposed Arrangement, the requestor (“Children’s Hospital”) would use funds from two individual donors to establish a restricted endowment fund that would subsidize patient... READ MORE

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OIG Issues Guidance on Real Estate Purchase from Entity Owned in Part by Excluded Individual

[10/11/19]

Posted on October 11, 2019 in Health Law News

Published by: Hall Render

On September 6, 2019, OIG issued Advisory Opinion No. 19-05 (“the Opinion”) regarding the proposed purchase of real estate from an entity owned and managed, in part, by an excluded individual. The facts that gave rise to the Opinion involved a community health center receiving federal grant funding and Medicare reimbursement which was looking... READ MORE

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Digital Medicine: OIG Approves Arrangement to Provide Smartphones to Patients

[02/15/19]

Posted on February 15, 2019 in Health Law News

Published by: Hall Render

On January 29, 2019, the Department of Health and Human Services Office of Inspector General (“OIG”) published Advisory Opinion 19-02, which approved an arrangement allowing a pharmaceutical manufacturer to loan smartphones to financially needy patients in order to assist with medication adherence. OIG stated that it would not impose sanctions against the parties for... READ MORE

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