February 5, 2014

In the first OIG Advisory Opinion of 2014, the OIG addressed whether a referral contract between senior communities and a placement agency violates the Anti-Kickback Statute ("AKS"). The OIG concluded that, even though payments made under the contract implicate the AKS, it would not impose any administrative sanctions due to a number of unique factors.

According to the OIG, the unique facts of the arrangement reduced any risk that the senior communities improperly paid the placement agency to induce referrals of or generate federal health care program business.

To read the full Alert, click here.