decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 2000 OIG Advisory Opinions / Opinion 00-01 - Consulting Firm May Make Percentage-Paid Audits of Hospital Bills
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Article Overview
This article summarizes an OIG advisory opinion from 2000 concerning a hospital’s arrangement with a consulting firm for retrospective bill audits and related follow-up activities. It is useful for compliance, revenue integrity, and healthcare legal teams that track federal fraud and abuse guidance, particularly when assessing compensation structures and audit arrangements in non-federal payer settings. The article focuses on the general facts of the arrangement, the types of services involved, and the OIG’s stated basis for its conclusion.
Why This Topic Matters
Advisory opinion summaries help readers understand how federal fraud and abuse authorities evaluate common hospital contracting and audit relationships. This one is relevant to organizations reviewing consulting arrangements, retrospective billing reviews, and compliance risk in mixed-payer environments.
What You Will Learn
- The general facts of a hospital consulting and audit arrangement
- How an OIG advisory opinion frames anti-kickback risk in a billing review context
- What types of operational safeguards and scope limitations were relevant to the opinion
- How retrospective audit arrangements are evaluated in relation to federal healthcare program business
Who Should Read This
- Healthcare compliance officers
- Hospital revenue cycle professionals
- Healthcare attorneys
- Coding and billing managers
- Audit and internal control teams
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