Frequently Asked Questions About the “Company Model”

On June 1, 2012, the Department of Health and Human Services Office of Inspector General (HHS-OIG) issued an Advisory Opinion (No. 12-06) on a "company model" arrangement and expressed the view that it could violate the federal anti-kickback statute. 

In order to provide assistance to our members, ASA has created an FAQ document with answers to some of the most frequently asked questions regarding the “company model” and the Advisory Opinion.  The document will be updated as warranted.

Review ASA’s FAQs.

Review the HHS-OIG Advisory Opinion.