OIG Issues Advisory Opinion Addressing “Swapping” Arrangements

The Department of Health and Human Services Office of Inspector General (OIG) recently issued Advisory Opinion 11-11 (issued July 28, 2011, posted August 4, 2011) in response to a request by a supplier (the Supplier) to skilled nursing facilities (SNFs) of medical supplies, equipment and related services. The OIG ultimately determined that the arrangement exhibited a link between Medicare covered services and non-covered services that would pose a substantial risk of violating the Anti-kickback Statute.

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