ASA Renews Request for Action from OIG on Company Model

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.

OIG "Company Model" Letter - June 16, 2010