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HHS OIG Issues Advisory Opinion on Continuing Medical Education, Stark Law Violations, Policy & Medicine

Wednesday, July 27, 2022

A recent LawFlash authored by partner Banee Pachuca and associate Felicia Alexander was cited in a Policy & Medicine article analyzing the US Department of Health and Human Services (HHS) Office of Inspector General’s (OIG’s) recent release of the Advisory Opinion No. 22-14, highlighting fraud and abuse considerations for provider-sponsored continuing education programs.

Referencing a Morgan Lewis advisory on topics including the Anti-Kickback Statute (AKS), the article notes that “with respect to healthcare transaction due diligence, buyers should ask about the target’s marketing and business development activities to identify any sponsored continuing education program activities. Then, the programs should be “thoroughly reviewed to detect any behavior that could generate material AKS risk.””

Read the full Policy & Medicine article >>