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Advisory Opinion 01-18

Concerning an exclusive contract for emergency ambulance services between County A, State B and Medical Center C under which County A has assumed the obligation to pay otherwise uncollected coinsurance amounts on behalf of County A residents. Specifically, whether such an arrangement would constitute grounds for the imposition of sanctions under the exclusion authority at section 1128(b)(7) of the Social Security Act (the "Act") or the civil monetary penalty provision at section 1128A(a)(7) of the Act, as those sections relate to the commission of acts described in section 1128B(b) of the Act, or under the civil monetary penalties provision for illegal remuneration tobeneficiaries at section 1128A(a)(5) of the Act.

Advisory Opinion 01-18