tci Part B Insider - 2009 Issue 11

COMPLIANCE: OIG Advisory Opinion Process Can Be Long,Arduous -- And Costly

The Advisory Opinion will give you peace of mind, so proceed with requesting one if you think youre on shaky ground. Last week, we showed you a few of the ins and outs of requesting an Advisory Opinion -- now get ready for the realities of using the OIGs process. Legal ramifications: Several subscribers wrote to us and asked whether the OIG could use the information in an Advisory Opinion request to impose penalties on the practice. Reality: If your Advisory Opinion concerns a proposed arrangement and the OIG issues an unfavorable opinion, the OIG generally assumes that the...

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