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OIG Approves Another Patient Assistance Program

06/18/2015
The Department of Health and Human Services, Office of Inspector General (“OIG”) issued Advisory Opinion No. 15-06 (the “Advisory Opinion”) regarding a 501(c)(3) charitable entity’s proposal to establish a program to provide financial assistance to individuals with cost-sharing obligations for prescription drugs or devices, health insurance premiums, and certain incidental expenses associated with treating various chronic diseases (“Proposed Arrangement”). The OIG concluded that the Proposed Arrangement would not constitute grounds for imposing civil monetary penalties, and, although it could potentially generate prohibited remuneration under the Anti-Kickback Statute, the OIG would not impose administrative sanctions.

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