decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 1999 OIG Advisory Opinions / Opinion 99-13 - No Discounted Pathology Services For Doctors
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Article Overview
This premium article reviews a 1999 OIG advisory opinion about a proposed discount arrangement involving pathology services and physicians. It explains the compliance and fraud-and-abuse issues the OIG considered, including the relationship to the federal Discounts Safe Harbor, differential treatment of federal and non-federal business, and a cited Special Fraud Alert. The content is relevant to compliance staff, billing professionals, healthcare counsel, and laboratory administrators who need to understand how advisory opinions evaluate referral-related pricing arrangements.
Why This Topic Matters
The opinion highlights how a discount strategy intended to improve competitiveness can still raise anti-kickback and fraud-and-abuse concerns when federal health care business is treated differently from other payer business. It is useful for organizations reviewing lab-physician financial arrangements and related compliance risk.
What You Will Learn
- The main compliance issues examined in a 1999 OIG advisory opinion involving pathology services
- How the opinion relates to the federal Discounts Safe Harbor
- Why differential treatment of payer classes can trigger fraud-and-abuse concerns
- How the cited Special Fraud Alert fits into the OIG’s analysis
Who Should Read This
- Compliance officers
- Healthcare attorneys
- Pathology and laboratory administrators
- Medical billing professionals
- Revenue cycle staff
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