Articles and Blogs

The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) posted Advisory Opinion 26-11 (“Advisory Opinion”) on May 20, 2026. This favorable opinion concerns a precision oncology company (“Requestor”) providing free supplemental reports to patients based on its algorithmic analysis, which functions as a Multi-Cancer Detection Test (“Algorithmic Analysis”). Although OIG... READ MORE

On May 1, 2026, the Department of Health and Human Services Office of Inspector General (“OIG”) posted Advisory Opinion 26-09 (“AO 26-09”), which opines on a pediatric dental and orthodontic service provider’s (“Requestor’s”) proposal to offer free orthodontic treatment for one patient per year at each of Requestor’s three practice locations (the “Proposed Arrangement”).... READ MORE

The Department of Health & Human Services (“HHS”) Office of Inspector General (“OIG”) recently reported five instances in which providers self-disclosed real estate arrangements and then subsequently settled alleged violations of the Civil Monetary Penalty (“CMP”) Law related to those arrangements, which were potentially tainted by kickbacks or Stark violations. The settlements for alleged... READ MORE

On December 23, 2020, the Department of Health and Human Services Office of Inspector General (the “OIG”) issued Advisory Opinion No. 20-08 (the “Advisory Opinion”) addressing the use of gift cards to incentivize patients to utilize health care services. While gift cards themselves are not a new topic for the OIG in the area... READ MORE

On July 11, 2019, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) released the new Grant Self-Disclosure Program Guidance (“Grant Guidance”) for HHS grant recipients and subrecipients. Through the Grant Guidance, OIG provides new self-reporting options for HHS grant recipients and subrecipients who determine that they... READ MORE