Law.com August 28, 2023
The opinion ultimately concludes that although the arrangement would generate prohibited remuneration if the requisite intent were present, the OIG will not impose administrative sanctions on the requestor under the act, as the sections relate to the federal anti-kickback statute and beneficiary inducements CMP.
The HHS Office of the Inspector General (OIG) issued Advisory Opinion No. 23-04 on July 6 regarding the use of and “proposed changes” to an online directory for health care professionals. Specifically, the “requestor” inquired as to whether the proposed changes would warrant sanctions under Section 1128A(a)(1) of the Social Security Act (act) as it relates to Section 1128B(b) (the federal anti-kickback statute), Section 1128A(a)(5) of the act (the beneficiary inducements CMP), or Section 1128(b)(7) as...
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