Tag Archives: ADVISORY OPINION

OIG Signs Up for Customer Loyalty Program

Photo of Robert M. WolinBy Robert M. Wolin on Posted in Uncategorized
In Advisory Opinion 17-05, posted by the U.S. Department of Health and Human Services Office of Inspector General (OIG) on September 7, 2017, the OIG approved a pharmacy’s customer loyalty/discount program (Benefit Program). Under the arrangement, members of the Benefit Program pay a fixed annual fee for access to the following benefits: Discounts on generic drugs, … Continue Reading

Destination Medicine: Not Just for the Rich and Famous

Photo of Katy ApplebyBy Katy Appleby and Banee Pachuca on Posted in Uncategorized
OIG okays providing modest hotel and meal accommodations for rural and financially needy patients. The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued an advisory opinion interpreting the finalized rules related to the beneficiary inducement civil monetary penalties (CMP) law. In a previous blog post, we discussed the OIG … Continue Reading
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