decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 2001 OIG Advisory Opinions / Opinion 01-06 - Vendor Fees Paid to GPO Fit Safe Harbor
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Article Overview
This summary reviews a 2001 OIG advisory opinion involving a group purchasing organization, vendor-based fees, and the Anti-Kickback Statute. It is relevant to compliance, fraud-and-abuse review, and healthcare contracting arrangements involving group purchasing organizations and provider relationships. The article gives a high-level account of why the arrangement was reviewed and the general basis for the OIG’s advisory view.
Why This Topic Matters
Healthcare compliance professionals, GPO administrators, and contracting teams may need to understand how vendor fee structures and ownership relationships can affect fraud-and-abuse analysis. The article provides context for evaluating arrangements under an OIG advisory opinion framework.
Article Sections
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Summary of the advisory opinion
Introduces the arrangement reviewed by the OIG and the general compliance issue raised by vendor fees in a group purchasing context.
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Reasons the arrangement was permitted
Outlines the broad factors the OIG cited in support of its advisory view, including contracting structure, purchasing authority, and disclosure practices.
What You Will Learn
- The general type of healthcare contracting arrangement reviewed in the advisory opinion
- Why vendor fee arrangements can raise fraud-and-abuse concerns
- The broad compliance factors discussed in the OIG summary
- How the article frames the role of disclosures and provider relationships in a GPO setting
Who Should Read This
- Healthcare compliance professionals
- Medical coders and auditors
- Group purchasing organization administrators
- Healthcare attorneys and contracting staff
- Revenue integrity teams
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