Vasilios J. Kalogredis, with Lamb McErlane. Courtesy photo. OIG Issues Favorable Opinion for Proposal to Pay Bonuses to Employed Physicians Based on Net Profits
The HHS Office of Inspector General (OIG) issued Advisory Opinion No. 23-07 (opinion) on Oct. 10 regarding a "requestor's" proposal to pay bonuses to its employed physicians based on net profits derived from certain procedures performed by the physicians (the proposed arrangement).
November 27, 2023 at 09:10 AM
5 minute read
The HHS Office of Inspector General (OIG) issued Advisory Opinion No. 23-07 (opinion) on Oct. 10 regarding a "requestor's" proposal to pay bonuses to its employed physicians based on net profits derived from certain procedures performed by the physicians (the proposed arrangement). Specifically, the requestor inquired as to whether the proposed arrangement would warrant sanctions under Section 1128(b)(7) or Section 1128A(a)(7) of the Social Security Act (SSA), as they relate to Section 1128B(b), the federal anti-kickback statute (AKS).
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