Notable OIG Advisory Opinion: Favorable Toward Employed Physician Bonuses Based on ASC Collections
In October 2023, the Department of Health and Human Services ("HHS") Office of the Inspector General (OIG) issued Advisory Opinion No. 23-07 ("AO") to a multi-specialty physician practice (the "Requestor") with 11 physician employees (the "Physicians"). The Requestor had inquired about the payment of bonuses to its employed physicians based on net profits from procedures performed by the Physicians ("Proposed Arrangement"). The Proposed Arrangement would implement a quarterly
Nov 22, 2023
