decisionhealth Newsletters, Answer Books - 2009 Issue 4 (April)
Anti-Kickback Advisory Opinion Summaries / 2003 OIG Advisory Opinions / Opinion 03-01 - Data Service Company May Employ Excluded Physician
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Article Overview
This advisory opinion summary explains how the Office of Inspector General approached a company’s proposed employment arrangement with an excluded physician. It is relevant to compliance, fraud-and-abuse review, and healthcare organizations that need to understand the general boundaries of employing excluded individuals when Medicare reimbursement is involved. The article focuses on the safeguards and separation principles discussed by OIG, without presenting detailed coding guidance.
Why This Topic Matters
Healthcare providers, compliance officers, and billing/reimbursement staff may need to evaluate employment relationships involving excluded individuals and Medicare-funded operations. Understanding the structure of this OIG opinion can help readers assess fraud-and-abuse risk and determine whether the full opinion is relevant to their compliance program.
What You Will Learn
- How OIG advisory opinions address employment of excluded individuals in a Medicare-related business environment.
- What general compliance considerations are raised when a company has both Medicare-related and non-Medicare-related activities.
- Which broad safeguards OIG discussed in connection with the employment arrangement.
- How advisory opinion summaries can inform fraud-and-abuse compliance review.
Who Should Read This
- Healthcare compliance professionals
- Medical practice administrators
- Revenue cycle and billing staff
- Healthcare attorneys
- Provider organizations
- Corporate compliance teams
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