COMPLIANCE:
Let The OIG Advisory Process Help Your Practice
Published on Fri Feb 27, 2009
Tip: Ask before you implement policies. You've most likely read one or two of the OIG's "advisory opinions" in the past, but rather than just know the rules for other practices, you can use this process to help your own. What is it: If you think one of your practice's actions might be in violation of the law (such as the civil monetary penalties or Stark laws), you can ask the OIG to analyze your case and make a determination regarding the legality of your arrangement. What it doesn't cover: The OIG will not address topics such as "model arrangements" or general questions of interpretation, among other issues, in advisory opinions. How to request one: If you'd like to ask the OIG to issue an advisory opinion on your situation, you should gather the required materials (including two copies of your request, your contact information, and an initial $250 fee) [...]