OIG Advisory Opinion 08-09 released

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:


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