decisionhealth Newsletters, Part B News - 2015 Issue 1 (January)
OIG advisory opinion: Charity can pay some copays for low-income patients
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Article Overview
This article summarizes an OIG advisory opinion involving a 501(c)(3) charity that sought to help low-income patients with treatment-related copayments and discusses why the opinion matters for compliance-minded providers, foundations, and donors. It also places the opinion in the context of prior OIG guidance, anti-kickback concerns, and the broader role of charitable assistance in helping patients access care.
Why This Topic Matters
The topic is relevant to health care compliance, physician referral practices, patient financial assistance programs, and charitable foundation operations. It helps readers understand the general regulatory environment surrounding third-party assistance for patients who have difficulty paying cost-sharing amounts.
Article Sections
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OIG advisory opinion overview
Introduces the advisory opinion and the charitable assistance arrangement being reviewed. Explains the general compliance context and the federal fraud-and-abuse concern at issue.
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Charity assistance structure and donor framework
Describes the proposed charity model, the patient population, and the types of information shared with donors. Covers the broad administrative features of the assistance program.
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Not the first time
Places the opinion in context with earlier OIG opinions involving charitable support. Summarizes how prior guidance has addressed similar assistance programs.
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How opinion could help your patients
Discusses the potential implications for providers and patients who may seek charitable help with cost-sharing. Covers the compliance, practice-management, and patient-referral considerations raised by the opinion.
What You Will Learn
- The general compliance issues addressed by an OIG advisory opinion on charity-funded patient assistance
- How charitable copay support programs are structured at a high level
- Why prior OIG opinions matter when evaluating similar assistance arrangements
- What kinds of provider and patient access issues are discussed in relation to indigent care support
Who Should Read This
- Physicians
- Health care compliance professionals
- Medical practice managers
- Health care attorneys
- Charitable foundation administrators
- Revenue cycle professionals
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