OIG Watch
Quick-read summaries of recent OIG advisory opinions.
OIG Advisory Opinion: 25-09
Physician-owners in a device company with proportional distributions
OIG Advisory Opinion: 25-08
Paying a third -party billing platform to retain hospital device sales
OIG Advisory Opinion: 25-07
Pharma-funded companion diagnostic testing for eligible patients
OIG Advisory Opinion: 25-04
Device vendor pays hospitals’ exclusion-screening / monitoring fees
OIG Advisory Opinion: 25-03
Leasing clinicians + bundled admin support in a digital health MSO model
OIG Advisory Opinion: 25-01
Free drug program for Medicare patients with unmet coverage
OIG Advisory Opinion: 24-13
Pharma-sponsored travel, lodging, and meals for patients receiving one-time T-cell therapy
OIG Advisory Opinion: 24-11
Free meningococcal vaccines tied to high-risk infusion therapy
OIG Advisory Opinion: 24-12
Drug company sponsors lab tests + counseling for rare kidney condition
OIG Advisory Opinion: 24-10
Loyalty points + tiered perks for dental supply customers
OIG Advisory Opinion: 24-09
Billing insurers but waiving all cost-sharing for on-scene EMS care
OIG Advisory Opinion: 24-08
Medicare Advantage plan sharing savings with employer groups via gainshare
OIG Advisory Opinion: 24-06
Gene therapy manufacturer covering $70K fertility services for eligible patients
OIG Advisory Opinion: 24-05
Patient travel and fertility preservation subsidies for $2M gene therapies
OIG Advisory Opinion: 24-04
Refunds + price protection discounts on ultra-rare one-time therapy
OIG Advisory Opinion: 24-03
Patient travel, lodging, and meals for gene therapy recipients
OIG Advisory Opinion: 24-02
Manufacturer-funded rare-disease patient assistance funds
OIG Advisory Opinion: 24-01
Medigap plan pays PHO % of savings for deductible discounts + offers patients $100 credit
OIG Advisory Opinion: 23-12
Retirement-triggered equity redemptions for physician-partners
OIG Advisory Opinion: 23-14
Medigap plan pays PHO % of savings for deductible discounts
OIG Advisory Opinion: 23-11
Clinical trial subsidies for Medicare cost sharing + site/investigator payments
OIG Advisory Opinion: 23-07
Profit-based bonuses for ASC-employed physicians
OIG Advisory Opinion: 23-06
Paying physician-linked labs for the technical component of commercial pathology tests
OIG Advisory Opinion: 23-05
Physician-owned IONM JV contracting ops back to MSO + affiliated practice
OIG Advisory Opinion: 23-04
Per-booking and ad fees on a patient search platform
OIG Advisory Opinion: 22-22
Free trial units of antipsychotic drug offered to hospitals
OIG Advisory Opinion: 22-21
Public EMS subleasing space and equipment to its private ambulance contractor
OIG Advisory Opinion: 22-20
Hospital-provided clinical support to independent physicians: when free NP services create remuneration requiring defensibility
OIG Advisory Opinion: 22-17
Health system forgives clinic debt tied to FMV lease and admin support
OIG Advisory Opinion: 22-14
Ophthalmology practice offering CE programs to referring optometrists
OIG Advisory Opinion: 22-13
Zero-interest financing program for DME customers, funded by third-party Lenders
OIG Advisory Opinion: 22-09
Lab specimen collection fees: when per-encounter payment structures fail even with FMV rates
OIG Advisory Opinion: 22-07
Physician ownership in entities they refer to: when equity structures create remuneration requiring defensibility
OIG Advisory Opinion: 22-05
Paying FMV site fees and patient cost-sharing in a CMS-approved device trial
OIG Advisory Opinion: 22-04
Digital health vendor fees + patient incentive programs: when provider payments raise kickback concerns
OIG Advisory Opinion: 22-03
Tuition + pre-cert pay for uncertified CNAs (often parents of patients)
OIG Advisory Opinion: 21-20
Per-click listing and platform fees for home health provider search site
OIG Advisory Opinion: 21-18
Therapy services joint venture where facility owner invests for 40% stake and controls referral stream
OIG Advisory Opinion: 21-15
Retaining net profits from CRNA services under a billing reassignment employment model
OIG Advisory Opinion: 21-06
Device pricing reduced when hospital takes over rep/distributor duties
OIG Advisory Opinion: 21-02
Health system + surgeons + management company investing in a new ASC
OIG Advisory Opinion: 20-07
Remittance-sharing platform for Medicare-secondary patients
OIG Advisory Opinion: 20-06
SNF-paid Medicaid application support services at below FMV
OIG Advisory Opinion: 19-04
Per-click and per-booking provider fees in a consumer healthcare search platform
OIG Advisory Opinion: 19-03
Free in-home CHF/COPD care after discharge from hospital
OIG Advisory Opinion: 18-14
Free inpatient drug supply to hospitals while maintaining high list prices elsewhere
OIG Advisory Opinion: 18-11
Incentive payments for increasing EPSDT screenings in a Medicaid MCO
OIG Advisory Opinion: 18-07
GPO serving both affiliated and unaffiliated facilities under uniform terms
OIG Advisory Opinion: 17-09
Physician gainsharing for surgical supply savings
OIG Advisory Opinion: 17-08
SNF network offering private-pay discounts based on quality scores
OIG Advisory Opinion: 16-13
Waiving cost-sharing and paying stipends to clinical trial participants
OIG Advisory Opinion: 16-12
Lab providing free administrative services to dialysis facilities to capture referral streams
OIG Advisory Opinion: 15-10
Leasing non-clinical staff + admin services at cost between related entities
OIG Advisory Opinion: 15-07
Paying Medicare copays and post-sham access in a device clinical trial
OIG Advisory Opinion: 14-06
Per-fill fees to local pharmacies for support services tied to patient referrals
OIG Advisory Opinion: 14-05
Pharmacy vendor fees for dispensing services in a direct-to-patient drug sales program
OIG Advisory Opinion: 14-03
Lab pays EHR vendor a per-order fee to become an 'in-network' referral option
OIG Advisory Opinion: 13-15
Psychiatry group capturing anesthesia revenue for ECT via below-FMV per diem
OIG Advisory Opinion: 13-11
Township subsidy covering residents' ambulance cost-sharing amounts
OIG Advisory Opinion: 13-10
Per-patient post-discharge support + tech platform to reduce readmissions
OIG Advisory Opinion: 13-09
GPO offers member equity for long-term lock-in and volume commitments
OIG Advisory Opinion: 13-05
Cost reimbursement to a municipality for dispatch services under an exclusive ambulance contract
OIG Advisory Opinion: 13-03
Private-pay lab turnkey model for physician practices
OIG Advisory Opinion: 13-02
Podiatrist-owned LLC selling orthotics to employers, overlapping with a Medicare-billing clinic
OIG Advisory Opinion: 12-22
Hospital paying cardiology group with fixed fee + performance bonuses for quality, patient satisfaction, and cost savings
OIG Advisory Opinion: 12-20
Hospital providing free electronic interface to physicians for ordering lab/diagnostic services
OIG Advisory Opinion: 12-19
Pharmacy providing free vs. FMV-priced software to community homes that influence referrals
OIG Advisory Opinion: 12-09
Therapy providers offering reduced rates for state-paid services while accessing Medicare/Medicaid residents
OIG Advisory Opinion: 12-08
IDTF employing physician whose family owns 70% when physician works with other referral sources
OIG Advisory Opinion: 12-06
Anesthesia group paying ASC 'management fees' + ASC-owned anesthesia subsidiaries
OIG Advisory Opinion: 11-17
Lab management services paid as percentage of physician's gross collections
OIG Advisory Opinion: 11-15
Physician-owned pathology lab management company with percentage-of-revenue fees
OIG Advisory Opinion: 11-11
Below-cost pricing on non-covered items swapped for exclusive Medicare Part B supply contract
OIG Advisory Opinion: 11-10
MSO administering state pay-for-performance payments on behalf of Medicaid program
OIG Advisory Opinion: 11-03
Turn-key pharmacy management for entity owned by LTC facilities that control referrals
OIG Advisory Opinion: 10-26
Below-cost ambulance service pricing for SNF Medicaid transport in exchange for federal referrals
OIG Advisory Opinion: 10-23
Per-test fees bundling sleep testing + marketing services in hospital deal
OIG Advisory Opinion: 10-24
Bundled equipment, staffing, and marketing services with separate FMV fees
OIG Advisory Opinion: 10-22
Fixed dispatch service fees based on cost allocation methodology
OIG Advisory Opinion: 10-16
Per-occurrence payments to referral sources with flawed FMV survey methodology
OIG Advisory Opinion: 10-15
50-50 joint venture with 100% interested investors based on FMV valuation
OIG Advisory Opinion: 10-14
Per-test fees for hospital "under arrangements" sleep testing services
OIG Advisory Opinion: 10-13
Free insurance pre-authorization services for referring physicians
OIG Advisory Opinion: 10-04
Free insurance pre-authorization services for referring physicians
OIG Advisory Opinion: 09-17
Multi-party ambulance joint venture with layered remuneration streams
OIG Advisory Opinion: 09-09
Hospital-physician ASC joint venture with tangible asset-only valuation
OIG Advisory Opinion: 09-06
Hospital paying physician groups 50% of cost savings from product standardization
OIG Advisory Opinion: 09-05
Hospital paying physicians for emergency on-call coverage for uninsured patients
OIG Advisory Opinion: 09-02
Employment concurrent with real estate purchase from the employee
OIG Advisory Opinion: 08-24
Multi-specialty group practice investment with non-practitioner equity holder
OIG Advisory Opinion: 08-22
Part-time physician employment arrangements for endoscopy services
OIG Advisory Opinion: 08-16
Hospital sharing private insurer quality bonus compensation with physician entity
OIG Advisory Opinion: 08-15
Multi-year gainsharing with annual rebasing to prevent duplicate payments
OIG Advisory Opinion: 08-12
Per-service administrative fees that don't fit the safe harbor
OIG Advisory Opinion: 08-10
Block lease with FMV pricing still flagged as profit-sharing scheme
OIG Advisory Opinion: 08-09
Percentage-based gainsharing that doesn't fit the safe harbor
OIG Advisory Opinion: 08-08
Hospital-physician ASC joint venture with surgeon-investors who don't regularly use the facility
OIG Advisory Opinion: 08-06
Laboratory offering free specimen labeling services to dialysis facilities to secure referrals
OIG Advisory Opinion: 08-03
Prompt pay discounts must be proportionate to avoided collection costs
OIG Advisory Opinion: 07-21
Hospital-physician gainsharing, paying surgeons 50% of cost savings from specific supply reduction measures
OIG Advisory Opinion: 07-20
Physician-owned imaging center in hurricane-devastated medically underserved area
OIG Advisory Opinion: 07-19
Hospital-based radiology group providing written reports without charge as part of exclusive arrangement
OIG Advisory Opinion: 07-13
Adding optometrist owners to single-specialty ophthalmology ASCs
OIG Advisory Opinion: 07-10
Physician ED on-call coverage compensation — per diem payments for call rotation and uncompensated care
OIG Advisory Opinion: 07-05
Hospital buying ASC ownership from select physician investors at appreciated price