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    • OIG Issues Advisory Opinion on Manufacturer-Subsidized Patient Reminder ProgramJune 13th, 2011

      By Peter M. Jaensch & Alan M. Kirschenbaum – The Office of the Inspector General (“OIG”) of the Department of Health and Human Services has issued a favorable Advisory Opinion on a manufacturer-sponsored patient reminder program for a vaccine, concluding that OIG will not seek penalties under …

    • Notorious Affiliate Exclusion Provision of PPACA RepealedDecember 21st, 2010

      By Alan M. Kirschenbaum – Exclusion from Medicare and Medicaid is a potent weapon used by the government against program-related fraud, but it can be a double edged sword when wielded against drug and medical device companies.  Exclusion of a drug or device company means that …