22 Advisory Opinions Issues by the Office of Inspector General – 6 of Interest; Anesthesia ASC Arrangements – 7 Key Concepts; and ASC Anti-Kickback Safe Harbor Issues — 9 Key Concepts for 2013

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HHS' Office of Inspector General issued 22 advisory opinions in 2012. Six of these contain guidance specific to hospitals, surgery centers and other providers. These are briefly described below. The first three advisory opinions closely address issues that surgery centers and hospitals currently are facing while the remaining three address issues that may have peripheral importance, such as an advisory opinion concerning a radiology group that proposed to offer free pre-authorization services to physicians and patients which has potential application to hospital-based specialists and to independent practitioners.

This article also discusses (1) key concepts under the anti-kickback statute related to anesthesia-ASC relationships and (2) ASC anti-kickback safe harbor issues.

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