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DHHS OIG Posts Advisory Opinion On Device Sellerís Proposed Refund Program


The DHHS Office of Inspector General (OIG) said it would not impose sanctions on a sellerís proposal to offer hospitals a full refund if their fiscal intermediary denies payment for treatment with the device; the hospital purchases the blood filtering device to treat rheumatoid arthritis. Although the proposal could potentially violate the Anti-Kickback Statute as an inducement to hospitals to purchase items indirectly reimbursable by federal healthcare programs, the DHHS OIG said the refund program contained a number of safeguards that reduced the risk of fraud and abuse. For example, the OIG noted that the reimbursement guarantee was limited in time to the initial delivery, was limited in scope to Medicare claims denied through the first level of appeal, and was limited to a refund of the itemís purchase price.

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