Carol Saul quoted in Home Health Interactive

AGG Partner H. Carol Saul is quoted in an article titled “OIG’s letter raises a ruckus among automated hospital referral system suppliers,” published in Home Health Interactive (subscription may be required to view). The Department of Health and Human Services Office of Inspector General issued a new advisory opinion concluding that automated discharge planning software may violate Medicare’s anti-kickback statute because use of the software could lead to improper payments and possible administrative sanctions. Although advisory opinions from the OIG are simply indicators of OIG thinking, Ms. Saul advises that anyone to whom the advisory opinion may pertain modify their practices because both parties involved, the companies providing the software and the hospitals using it, could have exposure under the anti-kickback statute if the OIG can show a provider intended to violate the law by participating in an arrangement in which paying providers receive a competitive advantage in referrals.

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