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Legal Issues• Legal Resources Kern Augustine Conroy & Schoppmann, P.C. (member log-in required) Publications:
First, please register as a non-URMC User at: NOTE: Enter Media Site Passkey at the very bottom of the form: anesthpm08 Then log in at:
ASA has submitted a letter to the Office of Inspector General (OIG) renewing its March 19, 2009, request for a Special Advisory Bulletin regarding the “company model.” A recent independent legal analysis published in the CCH Health Care Compliance Letter (reprinted with permission) supports ASA’s position that the “company model” potentially violates the Federal anti-kickback and self-referral provisions of the Social Security Act.
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