At the end of April, the Office of Inspector General of the US Department of Health and Human Services (the OIG) published its second Advisory Opinion of the year interpreting the Anti-Kickback Statute.OIG Advisory Opinion 21-02 analyzed a proposed joint venture among a health system, a group of physicians, and a third-party management company to develop, own and operate an ambulatory surgical center (ASC). On the one hand, the Advisory Opinion breaks little new ground — indeed, it’s a little surprising that the opinion was requested, given the fact pattern. On the other hand, it provides a bit of good news — and also some curious implications — to the ASC industry. Continue reading >