OIG Advisory Opinions: Proposed Multifacility Electronic Interface, Patient Gift Card Incentives

January 11, 2013 | Strategic Insights for Ambulatory Care


A proposed free electronic interface between a hospital and local physician practices allowing the physicians to transmit lab and diagnostic test orders to and receive results from the hospital would not generate prohibited remuneration and therefore would not violate the federal antikickback statute, says the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) in a December 19, 2012, advisory opinion. Therefore, having determined that the proposed system would not create remuneration prohibited by the statute, OIG would not impose administrative sanctions on the hospital creating the electronic interface. The hospital, county-owned and in a Health Professional Shortage Area, plans to provide free access to an electronic interface to local physicians and practices, according to the opinion.

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