As a corporate compliance officer what modification would you advice to increase the odds that the marketing program will pass the OIG scrutiny? Did the Advisory Opinion help inform your advice?
Compliance in home health company
1. Do you agree that the result in 06-01 is different from 07-16 because of influence/personal contact?
2. Do you agree that the importance of personal contact/influence is minimized in 15-12?
3. As a corporate compliance officer what modification would you advice to increase the odds that the marketing program will pass the OIG scrutiny? Did the Advisory Opinion help inform your advice?
4. What is the likelihood that the OIG will change its view of the arrangement described in this Advisory Opinion on account of the amendments to the CMP provisions? Why and why not?
OIG Advisory Opinions 06-01 07-16 and 15-12 posted on the OIG website https://oig.hhs.gov/reports-and-publications/archives/advisory-opinions/index.asp
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