“any compensation arrangement between a seller and an independent sales agent for the purpose of selling health care items or services that are directly or indirectly reimbursable by a federal health care program potentially implicates the anti-kickback statute, irrespective of the methodology used to compensate the agent.”
Advisory Request No. 98-10 - Office of Inspector General
Advisory Request No. 98-10 - Office of Inspector General
oig.hhs.gov/fraud/docs/advisoryopinions/1998/ao98_10.htm
Sep 8, 1998 - 98-10. Dear [name redacted]: We are writing in response to your request for an advisory opinion, in which you asked whether the payment of a ...Advisory Opinions | Archives - Office of Inspector General
www.oig.hhs.gov/reports-and-publications/archives/advisory.../index.asp
Modification of Advisory Opinion 12-15 (correcting OIG advisory opinion 12-15 by ......98-10 (... whether the payment of a sales commission to an independent
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