decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Advisory Opinion Procedures / Anti-Kickback Statute Advisory Opinion Procedures / Facts Subject to Advisory Opinions
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Article Overview
This article covers the Department of Health and Human Services OIG advisory opinion process, focusing on what kinds of fact patterns may be considered and what types of requests will not be accepted. It is useful for compliance staff, healthcare attorneys, and billing or reimbursement professionals who need a high-level understanding of advisory opinion eligibility and request requirements. The discussion also references the governing federal regulation and the kinds of matters that must be tied to a specific party and arrangement.
Why This Topic Matters
Understanding the boundaries of the advisory opinion process helps organizations determine whether a proposed arrangement is eligible for OIG review before investing time in a request. The article is relevant to compliance planning because it clarifies the difference between a specific request and a general or hypothetical inquiry.
What You Will Learn
- What kinds of arrangements may be the subject of an OIG advisory opinion request
- What general categories of requests are outside the advisory opinion process
- What information a request should contain at a high level
- What factors can make a request unacceptable for OIG review
Who Should Read This
- Compliance professionals
- Healthcare attorneys
- Billing and reimbursement staff
- Provider organization administrators
Codes Discussed
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