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OIG Updates COVID-19 FAQ

The Department of Health and Human Services Office of Inspector General (“OIG”) maintains a Frequently Asked Questions (“FAQ”) resource on its website.  This resource addresses certain topics relating to the application of the OIG’s enforcement authorities during the COVID-19 public health emergency.  The FAQ document was updated on Tuesday of this week to provide further guidance to clinical laboratories interested in offering free COVID-19 antibody testing to certain Federal health care program beneficiaries.  The FAQ document is available here.

OIG Issues Advisory Opinion Regarding Forgiveness of Unpaid Medical Debt

The OIG issued Advisory Opinion No. 20-04, which responds to an inquiry regarding a charitable organization’s proposal to purchase or receive certain donations of unpaid medical debt owed by qualifying patients.  The charitable organization proposed a program where it would purchase this debt and then forgive the debt.  The OIG advised that even though this could potentially generate prohibited remuneration under the anti-kickback statute (if the requisite intent was to induce or reward referrals of Federal health care program business), the OIG would not impose administrative sanctions in connection with the arrangement.  The full advisory opinion is available here.

CMS and CDC Issue Announcement on Provider Reimbursement

The Centers for Medicare and Medicaid Services (“CMS”) and the Centers for Disease Control and Prevention (“CDC”) have issued an announcement regarding payment for health care providers who counsel patients, at the time of COVID-19 testing, about the importance of self-isolation (after testing and prior to the onset of symptoms).  CMS intends to use existing evaluation and management (E/M) payment codes to reimburse providers who are eligible to bill CMS for counseling services.  The press release is available here.
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