Client Alert

OIG Advisory Bulletin on Contractual Joint Ventures: Turn-Key Management Agreements Singled Out

June 01, 2003

Amy E. Cella

In its Special Advisory Bulletin of April 23, 2003, the Office of Inspector General identified certain “contractual joint ventures” involving a captive referral base that may violate the anti-kickback statute. The Bulletin expresses OIG’s suspicion of turn-key management agreements between two existing providers where the manager is also a competing supplier of Medicare reimbursable items or services.

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