The Department of Health and Human Services, Office of Inspector General (OIG) recently released an advisory opinion (Advisory Opinion 25-08) concluding that a  proposed arrangement between a medical device company and third-party software vendor could violate the Anti-Kickback Statute (AKS) if the requisite intent were present.

The proposed arrangement responded to customer requests that the medical device company use –– and pay licensing fees to access –– the vendor’s software to facilitate “bill-only item” transactions that occurred at the customer. Continue Reading OIG Says Proposal to Pay for Third Party Billing Portal Poses Unacceptable AKS Risk