Manatt Health January 9, 2023
On December 19, 2022, the Office of Inspector General of the U.S. Department of Health & Human Services (OIG) issued an advisory opinion blessing the use of hospital-employed nurse practitioners (NPs) to perform certain functions typically performed by the patient’s attending physician (the Arrangement). Advisory Opinion No. 22-20 (the Opinion) provides insight into the OIG’s views on a common compliance issue that has proven challenging for hospitals and health systems grappling with how to utilize NPs most effectively. Despite its favorable conclusion, the Opinion underscores the potentially significant fraud and abuse risks associated with allowing hospital-employed NPs to furnish services that benefit or alleviate the responsibilities of independent physicians.
Overview of the Arrangement
The Opinion involves an acute-care hospital (the...
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