Law360, New York (December 23, 2011, 12:54 PM EST) -- The U.S. Department of Health and Human Services, Office of Inspector General (OIG) recently issued Advisory Opinion 11-17 (issued Nov. 16, 2011, posted Nov. 23, 2011) in response to a request by a company (the requester) that proposed to provide allergy testing and immunotherapy management services to primary care physicians (the physicians).
The OIG ultimately determined that the arrangement could potentially pose a substantial risk of violating the anti-kickback statute, subject to the requisite finding of intent.
Under the proposed arrangement, the requester would provide personnel,...
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