JD Supra July 24, 2023
On July 11, 2023, OIG posted Advisory Opinion 23-04 regarding the use of an online healthcare directory for Federal healthcare program beneficiaries to find and book appointments with medical providers. Requestor sought OIG’s approval with respect to the use of the current version of the online directory as well as proposed changes to the platform. OIG determined that, although the arrangement would generate prohibited remuneration under the Anti-Kickback Statute (AKS) and the Beneficiary Inducements civil monetary penalty (CMP), it would not impose administrative sanctions in connection with the AKS or CMP.
The Arrangement
Requestor operates an online directory platform—through both its website and mobile application—that allows individuals to search for and book medical appointments with healthcare providers.
The platform does...
Today's Sponsors
Today's Sponsor