Vasilios J. Kalogredis, with Lamb McErlane.
On July 14, the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) issued Advisory Opinion 21-09 approving an arrangement between a private licensed offeror of Medicare Supplemental Health Insurance policies (Medigap) and a preferred hospital organization (PHO).
The Proposal
Under the proposed arrangement, the PHO contracts with hospitals to form a network. Each network hospital makes an agreement in writing with the PHO to discount the Medicare Part A inpatient deductibles payable by the Medigap plan. Accredited, Medicare certified, hospitals which satisfy licensing requirements, state laws and agree to discount Medigap’s Medicare Part A deductible costs can join the network. Each network hospital’s discount on the Medicare Part A inpatient deductible would be applied uniformly to all policyholders for a term of at least one year.
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