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Advisory Opinions

HHS-OIG issues advisory opinions about the application of certain fraud and abuse enforcement authorities to the requesting party’s existing or proposed business arrangements.

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Recent Activity

  • AO 23-05 was posted on August 18, 2023

    Unfavorable opinion regarding a company’s proposal to assist physicians who perform surgeries for which the company’s services are used with the formation and operation of a turnkey physician-owned entity that would perform those same services.

  • AO 23-04 was posted on July 11, 2023

    Favorable opinion regarding: (i) the use of a health technology company’s online health care directory by Federal health care program beneficiaries to search for and book medical appointments with providers and the display of sponsored advertisements to Federal health care program beneficiaries on the directory and certain third-party websites; and (ii) certain proposed changes to the functionality of the directory.

  • AO 20-04 was modified on April 24, 2023

    Modification of favorable opinion regarding a charitable organization’s proposal to purchase or receive donations of unpaid medical debt owed by qualifying patients from certain types of health care providers and then forgive that debt.

  • AO 23-03 was posted on March 29, 2023

    Favorable opinion regarding a proposal to provide a prepaid card to certain individuals, including Federal health care program beneficiaries, to encourage those individuals to return the sample collection kit associated with a colorectal cancer screening test.

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