decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 2006 OIG Advisory Opinions / Opinion 06-09 - Charity May Subsidize Health Care Payments For Kidney Disease Patients
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Article Overview
This article summarizes a 2006 OIG anti-kickback advisory opinion involving a non-profit charity that helps kidney disease patients with certain Medicare Part D-related expenses. It is relevant to compliance, legal, reimbursement, and patient assistance stakeholders who need a high-level understanding of the arrangement and the general factors OIG reviewed in assessing fraud and abuse risk.
Why This Topic Matters
It shows how OIG evaluated a charity-based patient assistance program and highlights the compliance considerations that matter when donors, charities, and beneficiaries are connected through subsidized health care support.
What You Will Learn
- The general structure of a charity-supported patient assistance arrangement.
- The kinds of program safeguards OIG reviewed in assessing fraud and abuse concerns.
- Why donor independence, recipient selection criteria, and patient choice are important in this advisory opinion context.
- How Medicare Part D-related assistance was part of the arrangement discussed.
Who Should Read This
- Compliance professionals
- Health care attorneys
- Medical billing and reimbursement staff
- Patient assistance program administrators
- Pharmacy and benefits stakeholders
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