decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Special Advisory Bulletins / OIG Special Advisory Bulletin 99-1_July 8, 1999 / The Special Advisory Bulletin
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Article Overview
This bulletin addresses how OIG views gainsharing arrangements in relation to federal fraud-and-abuse law. It is relevant to compliance, hospital administration, and physician contracting audiences who need a high-level understanding of the civil money penalty framework and the related anti-kickback and physician self-referral concerns discussed in the bulletin.
Why This Topic Matters
Hospitals and physicians needed guidance on whether existing or planned gainsharing arrangements could trigger federal enforcement concerns. The bulletin also signals the importance of prompt compliance review when arrangements involve Medicare or Medicaid beneficiaries.
Article Sections
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Civil Money Penalty section
Discusses the bulletin’s focus on civil money penalty concerns in connection with hospital-physician arrangements and the general compliance context addressed by OIG.
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Anti-Kickback Statute section
Summarizes the bulletin’s discussion of related anti-kickback considerations and how they connect to the broader fraud-and-abuse framework.
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Stark: Physician Self-Referral section
Covers the bulletin’s references to physician self-referral concerns and related federal restrictions mentioned by OIG.
What You Will Learn
- The compliance topics OIG associates with gainsharing arrangements
- How the bulletin frames civil money penalty concerns
- What related fraud-and-abuse laws are implicated at a high level
- Who should pay attention to the bulletin’s guidance
Who Should Read This
- Hospitals
- Physicians
- Compliance officers
- Healthcare attorneys
- Medical coding and reimbursement professionals
Codes Discussed
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