decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 1999 OIG Advisory Opinions / Opinion 99-06 - Copay Waivers Okay For Charity if Safeguards are Sufficient
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Article Overview
This article summarizes a 1999 OIG advisory opinion involving St. Jude Children’s Research Hospital and affiliated hospitals. It explains the general compliance context for charity-based waiver policies, the kinds of safeguards the OIG considered, and why the opinion may be relevant to health care compliance, hospital administration, and anti-kickback review. The piece is aimed at readers who need a high-level understanding of how advisory opinions address waiver practices and related organizational protections.
Why This Topic Matters
Advisory opinions like this help compliance, legal, and revenue-cycle teams understand how OIG evaluates charity waiver arrangements in provider settings. It is useful for assessing policy design, referral relationships, and organizational safeguards without relying on a full private opinion text.
What You Will Learn
- The general compliance issues surrounding charity-based cost-sharing waivers
- The types of organizational safeguards discussed in the advisory opinion context
- How the OIG framed the relationship between waiver policies and anti-kickback concerns
- Why hospital structure and referral dynamics can matter in advisory opinion analysis
Who Should Read This
- Healthcare compliance professionals
- Hospital administrators
- Health law attorneys
- Revenue cycle leaders
- Coding and billing compliance staff
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