On Dec. 29, 2015, the U.S. Department of Health and Human Services Office of Inspector General (OIG) responded to a request for an advisory opinion regarding allowing a hospital to bill a radiology group for transcription of the radiology group’s reports for people who are not hospital patients, but rather patients of a third-party medical clinic that provided the technical component of the radiology exams. The OIG was asked to look at the proposed arrangement to determine whether it believed that prohibited remuneration under the Anti-Kickback Statute (AKS) would be generated by this arrangement.
Facts
The hospital was a licensed acute-care hospital in a sparsely populated region. The clinic was a family practice in a rural community in that region. The clinic physicians were not members of the hospital staff. They did order certain diagnostic tests from the hospital and sometimes referred patients to the hospital. Therefore, they were referral sources for the hospital.
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