On Dec. 14, 2022, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) issued Advisory Opinion No. 22-20 that addresses a request from an acute-care hospital, that provides a range of inpatient and outpatient hospital-based services. The hospital sought to determine whether its arrangement to utilize hospital's nurse practitioners (NPs) in providing Medicare and Medicaid beneficiaries with services that were previously only performed by participating physicians in certain units within one of the hospital's two campuses (the arrangement) may trigger the imposition of sanctions for potential violations under the federal anti-kickback statute (AKS) or the civil monetary penalties law (CMP) of the Social Security Act (the act).