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No Sanctions For Arrangement Between Senior Care Communities and Placement Agency

February 06, 2014

By PAUL A. GOMEZ & TOMER KONOWIECKI

In a recent advisory opinion, The Department of Health and Human Services Office of Inspector General ("OIG") stated that it will not impose sanctions on a percentage-based compensation arrangement between two senior care communities and a placement agency. The opinion appears to indicate that placement fee arrangements involving referrals to healthcare providers may survive scrutiny from the OIG in certain limited situations. Nevertheless, healthcare providers should continue to carefully assess whether to enter into placement arrangements.

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