OIG Advisory Opinion 08-09 released

Written by Reed Tinsley | August 18, 2008

The OIG reiterated its position regarding gainsharing, but this time in the context of two new medical specialties—orthopedic surgery and neurosurgery. After reviewing the arrangement established by the requestors, the OIG found that the arrangement implicated the anti-kickback statute and civil monetary penalty (CMP) provisions of the Social Security Act, 42 U.S.C. 1320a-7b and 1320a-7a, respectively, but concluded, consistent with its earlier gainsharing opinions, that it would not impose civil monetary penalties or administrative sanctions:

http://oig.hhs.gov/fraud/docs/advisoryopinions/2008/AdvOpn08-09B.pdf

About the Author

Reed Tinsley CPA

This article is written by Reed Tinsley, a Houston, TX-based CPA with over 30 years of experience advising physicians and medical practices across Texas and the United States. Reed holds certifications as a Certified Valuation Analyst (CVA), Certified Healthcare Business Consultant (CHBC), and Certified Financial Planner (CFP), specializing exclusively in the healthcare sector. He is a published author, nationally recognized speaker, and trusted advisor to physicians on accounting & tax, practice management, and financial planning. Schedule a Free Consultation.

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