Tag Archives: Per Click

OIG Approves “Per Click” Sleep Venture

 In OIG Advisory Opinion No. 10-14, the OIG concluded that it would not seek enforcement of the Anti-Kickback Statutes under an arrangement in which an independent sleep testing provider entered into an arrangement to provide a hospital-owned sleep testing facility with equipment and staff on a per test basis.… Continue Reading

October 1, 2009: Effective Date of New Stark Rules

This is just a reminder of the effective date for certain new Stark Rules: 1.         CMS prohibits percentage formulae conjunction with space on equipment leases, fair market value exception transactions and indirect compensation effective October 1, 2009. 2.         Per click leases are prohibited effective October 1, 2009. 3.         "Under arrangement" relationships have been changed because … Continue Reading