By: Clay J. Countryman

Several recent advisory opinions issued by the U.S. Department of Health and Human Services Office of Inspector General (OIG) have addressed common aspects to physician practice business relationships with hospitals and other providers. Although the OIG’s comments in an advisory opinion are limited to a specific proposed arrangement, the OIG’s comments indicate how certain aspects of a hospital’s current or proposed arrangement with physicians may be scrutinized under the Federal anti-kickback statute and other fraud and abuse laws.