Arrangements between and among medical service providers and others in the health care industry are highly regulated, in particular due to governmental concerns about fraud and abuse. Health care providers, and those they do business with, therefore must be careful when entering into arrangements for the provision of services. This may be especially so when the services offered are free-of-charge or below-market value.

On August 30, the Department of Health and Human Services (HHS), Office of Inspector General (OIG), issued a favorable advisory opinion (No. 12-10), permitting a radiology group to provide pre-authorization services free of charge to physicians and patients under the federal Anti-Kickback Statute.

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