“Although the … arrangement could potentially generate prohibited remuneration under the … statute, if the requisite intent to induce or reward referrals of federal healthcare program business were present, the OIG will not, and would not, respectively, impose administrative sanctions on” the medical center under the rules, the inspector general wrote in an opinion, in which the medical center name and location were redacted.
The decision came in response to the medical center’s request for an advisory opinion regarding a program it offers that provides free, in-home follow-up care to eligible congestive heart failure patients. The medical center also sought an opinion regarding a proposed expansion of this program that would include certain chronic obstructive pulmonary disease patients.
The unnamed medical center developed a program to offer in-home follow-up care to patients it deemed high-risk of admission or readmission to a hospital. The goal of the program is to improve patient compliance with discharge plans, boost patient health, and decrease inpatient admissions and readmissions.
Read the OIG’s full opinion here.
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