Five Recent OIG And HHS Advisory Opinions

The Office of Inspector General ("OIG") issued four advisory opinions at the end of 2020 addressing gift cards and paying for expenses, among other issues. With regard to all of these requests, the OIG analyzed whether the proposed arrangements in these requests would constitute grounds for the imposition of sanctions under the Social Security Act (the "Act") and the federal anti kickback statute (the "Anti-Kickback Statute").

In addition, the Department of Health and Human Services ("HHS") Office of the General Counsel ("OGC") released an advisory opinion clarifying who is covered under the 340B program.

Medicare Enrollment Application Assistant Services for Nursing Homes and Home Health Agencies