decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 1998 OIG Advisory Opinions / Opinion 98-18 - Ophthalmologist May Sublease Equipment to Optometrist
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Article Overview
This Find-A-Code article reviews a 1998 OIG advisory opinion involving an ophthalmologist and an optometrist and discusses how the Office of Inspector General evaluated a proposed equipment sublease arrangement in relation to Anti-Kickback Statute concerns. It is relevant to compliance staff, coders working with healthcare business arrangements, and professionals tracking OIG advisory opinions and safe harbor guidance. The article focuses on the general structure of the arrangement, the factors OIG considered, and the conditions that affected the opinion’s limited applicability.
Why This Topic Matters
Understanding OIG advisory opinions helps readers assess whether a proposed healthcare business arrangement may raise Anti-Kickback concerns and what compliance considerations were important in the agency’s analysis.
What You Will Learn
- The general compliance context for an OIG advisory opinion involving an equipment sublease arrangement
- How telemedicine-related services were evaluated from an Anti-Kickback perspective
- What broad factors OIG considered in its safe harbor analysis
- Why the opinion’s applicability depended on ongoing compliance with stated conditions
Who Should Read This
- Healthcare compliance professionals
- Medical coders and coding auditors
- Practice administrators
- Physicians and other clinicians involved in referral-sensitive arrangements
- Legal and regulatory staff
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