decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 1998 OIG Advisory Opinions / Opinion 98-15 - Contract Pharmacy May Facilitate Outpatient Drug Program
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Article Overview
This advisory opinion summary reviews an OIG analysis of a university’s proposed contract pharmacy arrangement for outpatient drug dispensing and related pharmacy support services. It explains the general compliance context involving HRSA guidelines, the 340B program, the Public Health Service Act, and the Maternal and Child Health Services Block grant program. The article is useful for compliance, pharmacy, and health care reimbursement professionals evaluating federally supported outpatient drug arrangements and anti-kickback risk.
Why This Topic Matters
It helps readers understand how OIG views a contract pharmacy model in the context of federal outpatient drug discount and compliance programs. The summary is relevant to organizations assessing whether a proposed pharmacy services structure aligns with government program requirements and anti-kickback concerns.
What You Will Learn
- The compliance context for a university contract pharmacy arrangement
- How the 340B program and related federal guidance are discussed in an advisory opinion summary
- The relationship between outpatient drug dispensing services and anti-kickback risk considerations
- Why federal grant-supported hemophilia services are relevant to the arrangement
Who Should Read This
- Compliance officers
- Medical coders
- Pharmacy administrators
- Health care attorneys
- Revenue cycle professionals
- Hospital and clinic managers
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