Working with Lead Generation Companies
AMARILLO, TX - The Department of Justice (DOJ) and Office of Inspector General (OIG) are scrutinizing arrangements that health care providers and suppliers (pharmacies, labs, DME suppliers, etc.) have with lead generation companies (LGCs).
Re-Starting the 36-Month Oxygen Rental Period
A new 36-month rental period can begin only in the following situations: After the five year reasonable useful lifetime (“RUL”) of the oxygen equipment has expired, if the beneficiary elects to obtain new oxygen equipment.
Baird: Latest On Loan Closets
AMARILLO, TX - A “loan closet” is also known as a “stock and bill”...which is also known as a “consignment closet.” A DME supplier can set up a loan closet arrangement at a hospital, clinic, or physician’s office (“Facility”).
Interest-Free Financing: OIG Advisory Opinion
AMARILLO, TX - The federal anti-kickback statute (“AKS”) is very broad. The AKS makes it a criminal offense to knowingly and willfully offer, pay, solicit, or receive any remuneration...
Compensating Marketing Reps of Affiliated Companies
AMARILLO, TX - One of the safe harbors is the “Employee Safe Harbor.” It states that if a person is a bona fide employee (full-time or part-time) of a provider/supplier, the compensation paid to the employee does not violate the AKS.
Negotiating Managed Care Contracts
AMARILLO, TX - Historically, DME suppliers have taken care of Medicare patients and have billed CMS directly. This is known as “Medicare fee-for-service” (Medicare FFS). Also, historically, suppliers have taken care of state Medicaid patients.