The Office of Inspector General (“OIG”) for the Department of Health and Human Services recently issued an Advisory Opinion that provides insight into how the agency evaluates arrangements that deal with the integration of technology, medicine, and patient monitoring under the federal Anti-Kickback Statute (“AKS”). In Advisory Opinion No. 19-02, OIG evaluated whether a pharmaceutical manufacturer could temporarily loan a limited-functionality smartphone to financially needy patients enrolled in federal health care programs. OIG concluded that the proposed arrangement could violate federal health care fraud laws but OIG would not impose civil monetary penalties or administrative sanctions in light of the purpose of the arrangement and certain safeguards in place. This Advisory Opinion related to the promotion of remote patient monitoring and is useful to telehealth providers and other pharmaceutical manufacturers to evaluate how OIG might analyze similar arrangements.
Monthly Archives: March 2019
Maxima Legal is developing the PPP legal concept for the construction of a tram line between two parts of the Russian Federation
Maxima Legal has been selected following a tender to develop the technical and economic scheme for the construction of a tram line between St Petersburg and Leningrad oblast on the basis of a concession agreement.
In a recent decision involving the cash-in-transit industry, the full bench of the Fair Work Commission upheld a decision to reinstate an armoured vehicle operator (AVO) after his successful unfair dismissal application.1
Recent amendments to the PBR Act have strengthened PBR rights and have aligned aspects of PBR with other intellectual property laws in Australia.