New OIG Advisory Opinion 11-18

The OIG has released its most recent Advisory Opinion (#11-18).  This Opinion was issued on November 30, 2011 and was posted on December 7, 2011.

The Opinion deals with the legalities of an online service that would facilitate the exchange of information between health care practitioners, providers, and suppliers.

In the end, the opinion concludes that although the Proposed Arrangement could potentially generate prohibited remuneration under the anti-kickback statute if the requisite intent to induce or reward referrals of federal health care program business were present, the OIG would not impose administrative sanctions in connection with the Proposed Arrangement.

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