Lexology August 12, 2025
It has been a busy summer for telehealth updates. Following is a high-level summary of the latest developments.
On June 6, 2025, the Office of Inspector General of the U.S. Department of Health and Human Services (the “OIG”) issued an advisory opinion (25-03), which may provide a model for structuring telehealth collaborations that are compliant with federal and state laws and enable expanded patient access, particularly in rural and underserved communities. A management services organization and its affiliated physician entity (“PC”) proposed an arrangement with telehealth providers and their management platforms (“Telehealth Co.”) under which the PC would lease the services of Telehealth Co healthcare professionals to provide services to PC’s patients, after being enrolled and credentialed in PC’s payor...
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