A state's plan for Medicaid pay-for-performance disbursements, and a proposed plan to market a dental network to patients were found to pose minimal kickback risks, while a proposal by a durable medical equipment (DME) manufacturer to provide advertising and reimbursement consultation services to its suppliers and beneficiaries would likely be subject to administrative sanctions. The Office of Inspector General (OIG) explained its position for each of these proposals in three advisory opinions issued from October 6 - 13, 2006.
OIG Advisory Opinion, No. 06-15, Oct. 6, 2006, Health Care Compliance Reporter ¶500,149. OIG Advisory Opinion, No. 06-17, Oct. 13, 2006, Health Care Compliance Reporter ¶500,151. OIG Advisory Opinion, No. 06-16, Oct. 10, 2006, Health Care Compliance Reporter ¶500,150.
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