OIG Advisory Opinion Finds Hospital Discharge Referral Software Creates Anti-Kickback Risk
The HHS Office of Inspector General issued Advisory Opinion 26-15 concluding that a subscription-based referral management software platform used in hospital discharge planning could generate prohibited remuneration under the Federal Anti-Kickback Statute. OIG determined that providers paying subscription fees to use the platform may receive improper referrals in exchange for those payments. The opinion affects hospitals, post-acute care providers, and technology vendors involved in discharge planning and care coordination arrangements. The advisory opinion provides immediate compliance guidance for similar arrangements nationwide.
This unfavorable opinion signals heightened OIG scrutiny of technology-enabled referral arrangements in discharge planning, requiring Medicaid providers and managed care organizations to review discharge coordination software contracts for AKS compliance risks.
Long-Term Care · LTSS
You might also like