Anti-Kickback Advisory Opinion Summaries / 2006 OIG Advisory Opinions / Opinion 06-22 - Hospital May Reward Surgeons in Cost-Saving Plan

Why This Topic Matters

Health care organizations use advisory opinions to understand how federal fraud-and-abuse authorities may view financial arrangements that affect clinical practice and hospital operations. This article helps readers assess the broad compliance considerations involved in cost-saving incentive programs without relying on the full advisory opinion text.

Article Sections

1. Advisory opinion summary

   Overview of the hospital’s proposed surgeon incentive arrangement and the general compliance concerns raised by the arrangement.

2. Civil monetary penalty concerns and safeguards

   Discussion of the civil monetary penalty issues considered by OIG and the types of safeguards described in the opinion.

3. Anti-Kickback Statute concerns and risk-limiting features

   Summary of the Anti-Kickback Statute considerations and the general features identified as reducing fraud-and-abuse risk.

4. Related resources

   Pointer to related discussion of gainsharing and cost-saving arrangements.