Anti-Kickback Advisory Opinion Summaries / 2001 OIG Advisory Opinions / Opinion 01-07 - Long Standing Insurance-Only Billing Policy Survives

Why This Topic Matters

The article helps readers understand how OIG may assess long-standing billing policies, physician employment arrangements, and related risk factors in a fraud-and-abuse context. It is useful for organizations that want to compare their own practices against the type of considerations discussed in the advisory opinion.

Article Sections

1. Advisory Opinion Overview

   Introduces the specialty hospital policy reviewed by OIG and the general context of the advisory opinion. Summarizes the broad compliance questions addressed in the opinion.

2. OIG Analysis of In-Patient Medicare Part A Policy

   Describes OIG’s review of the hospital’s billing approach for certain in-patient beneficiaries. Covers the general category of waiver-of-coinsurance analysis.

3. OIG Analysis of Physician Employee Services

   Summarizes OIG’s discussion of physician employment arrangements and related risk considerations. Addresses the broader factors OIG considered in evaluating this part of the policy.

4. OIG Analysis of Part-Time Outside Work and Outside Privileges

   Summarizes the later practices discussed by OIG involving physician participation outside the hospital. Covers the agency’s competitive-concern analysis at a high level.