decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 2007 OIG Advisory Opinions / Opinion 07-15 - Medigap Credits Passes Scrutiny
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Article Overview
This summary reviews an OIG advisory opinion from 2007 addressing a proposed Medigap arrangement that offered renewal premium credits connected to use of preferred hospitals. It explains the compliance issues the OIG considered, including federal fraud-and-abuse and civil monetary penalty concerns, and why the proposal was viewed as posing limited risk under the described facts. The article is relevant to compliance professionals, insurers, provider organizations, and medical coders who track regulatory guidance affecting Medicare-related benefit arrangements and patient incentives.
Why This Topic Matters
OIG advisory opinions help organizations evaluate whether benefit designs, contracting arrangements, and patient incentives may raise federal fraud-and-abuse concerns. This article is useful for understanding how Medicare-related cost-sharing and insurer marketing practices can be analyzed within that regulatory framework.
What You Will Learn
- The general compliance issues raised by a Medigap incentive arrangement
- How the arrangement was framed in relation to federal fraud-and-abuse review
- Why Medicare-related payment structure and beneficiary choice were discussed
- The kinds of OIG considerations that influence advisory opinion outcomes
Who Should Read This
- Compliance professionals
- Health plan administrators
- Insurance carrier staff
- Provider contracting teams
- Medical coding and reimbursement professionals
- Healthcare attorneys
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