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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 25-12 was posted on January 5, 2026

    Unfavorable opinion regarding a proposal for a home care agency to market sign-on bonuses to prospective employees with the intention of employing those individuals for the provision of services to other individuals, who most often would be family members of the prospective employees.

  • AO 25-11 was posted on December 18, 2025

    Favorable opinion regarding certain discount structures that that a pharmaceutical manufacturer offers on particular vaccines.

  • AO 25-10 was posted on September 11, 2025

    Favorable opinion regarding an arrangement pursuant to which a company operationalized and makes financial contributions to a foundation, and the foundation provides grants to families of children receiving a particular type of therapy.

  • AO 25-09 was posted on August 12, 2025

    Favorable opinion regarding remuneration to physicians with an ownership interest in a device manufacturer.

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