The vendor proposed selling hospitals a package of services involving a patient liaison who would help patients follow discharge instructions, with the aim of reducing readmissions and therefore helping hospitals avoid cuts to their Medicare reimbursement. The hospital would pay a flat fee for implementation services, which could include electronic health record data integration, and a per-patient fee for specific services the hospital chooses for individual patients.
The vendor has a separate sales department from its parent company and would not receive payment for any drug sales. In addition, neither the vendor nor the patient liaison would recommend patients seek care at providers outside of the patient’s designated regular providers.
The OIG concluded that the proposal “presents a sufficiently low risk of fraud and abuse under the antikickback statute” and “would not constitute grounds for the imposition of civil monetary penalties.”
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