Alerts8.25.23

HHS-OIG Issues Unfavorable Advisory Opinion Concerning Physician-Owned Turnkey Arrangement

Medical professional

Highlights

The U.S. Department of Health and Human Services issued an unfavorable opinion addressing physician-owned joint ventures

The agency determined the arrangement posed a significant risk of overutilization or increased costs to federal health programs because multiple streams of revenue could corrupt medical decision-making

The opinion reiterates the HHS-OIG’s long-standing position against certain “carve out” arrangements in joint ventures


The Office of Inspector General of the U.S. Department of Health and Human Services (HHS-OIG) recently issued Advisory Opinion No. 23-05 regarding a turnkey arrangement. The arrangement involved an intraoperative neuromonitoring (IONM) service provider that would offer its surgeon referral sources the opportunity to form and own a turnkey IONM business managed and operated entirely by the IONM service provider and its affiliates.

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