Phone: 302.658.4265


Negative OIG Advisory Opinion Regarding Exclusive Arrangements Between Labs and Physician Practices

On March 25, the Department of Health and Human Services Office of Inspector General (“OIG”) released Advisory Opinion 15-04 in which it concluded that an exclusive arrangement between a laboratory (“Requestor Lab”) and physician practices could generate prohibited remuneration under the anti-kickback statute. Furthermore, the OIG concluded that the proposed arrangement could violate the prohibition on charging Federal health care programs substantially in excess of usual charges, for which a provider may be excluded from participation in Federal health care programs.

Read More

HHS Office of Inspector General Fraud and Abuse Focus: FY 2015 Work Plan

Each year, the Office of Inspector General (“OIG”) at the Department of Health and Human Services announces the agency’s new and continuing initiatives to combat health care fraud and abuse. The annual OIG Work Plan helps health care providers understand new, and some recurring, areas that the OIG believes are key in the fight to protect the federal fisc. We have previously discussed such key initiatives to help Delaware providers identify and focus on potential areas of compliance risk before issues arise.

Read More

  • Navigating Delaware's Legal Landscape