OIG still watching PODs closely; review the list of suspect arrangements

Why This Topic Matters

POD arrangements can create significant fraud-and-abuse risk, especially when ownership, referrals, purchasing patterns, or facility relationships raise anti-kickback concerns. Understanding the OIG’s view helps organizations assess compliance exposure before structuring or investing in these relationships.

Article Sections

1. Compliance

   Introduces the compliance concerns associated with physician-owned distributorships and the general scrutiny such arrangements can attract.

2. PODs excluded from new safe harbors

   Summarizes the recent OIG guidance and its relationship to the anti-kickback framework and value-based arrangement safe harbors.

3. 7 characteristics that are particularly suspect

   Outlines categories of ownership, purchasing, referral, operational, and disclosure-related features that may heighten concern about a POD arrangement.

4. 5 characteristics that increase fraud risk

   Describes broader indicators that may be relevant to assessing risk and intent in a POD structure.

5. Resources

   Provides references to external OIG materials and related federal guidance.