Legal Update

Lessons learned; The joint venture in question; The OIG's view; On the Web; ASCs; Advisory Opinion; Anti-kickback Statute; Anti-kickback Statute. Concluding; Concluding; General; Inspector General; July; Medicare-covered ASC; OIG; OIG Advisory Opinion; OIG's; Office; Opinion; Statute; Statute. Concluding; Web Advisory Opinion; ability; addresses; adopt; advisory; agreed; ambulatory; answers; applying; approves; arrangement; based; business; care; carefully; certified; clarifies; comforts; companies; concern; concluded; confines; counsel; demonstrates; derived; determined; development; differ; direct; discouraged; due; employ; employing; endorses; equal; established; evaluate; experienced; extension; facts; fall; favorable; federal; final; fiscal; fraud; generate; guidelines; hand; harbor; harbors; health; hospital; hospital-physician; hospitals; impede; impose; income; incorporated; indirect; influence; interest; interested; interests; investing; investment; investors; involved; involves; issue; joint; legal; liability; likelihood; limited; long; made; make; management; medical; meet; met; minimize; multi-site; notes; number; offers; one-third; opinion; orthopedic; owned; ownership; passive; patients; percent; perform; permitted; personally; physician; physician-hospital; physician-investors; physicians; place; points; poised; portion; position; potential; potentially; practice; primary; procedures; profit; profiting; proportional; proposed; protections; pursuing; qualify; raises; rarely; rationale; redirect; refer; referral; referring; regulatory; remaining; requires; requiring; restrictions; return; revenues; review; reward; riskier; rule; ruling; safe; safeguards; shied; short; significant; simply; situational; small; sources; specific; specifically; states; strict; structure; substantial; suggests; surgeon; surgeon-investor; surgeons; surgery; surgical; systems; total; track; true; turn; vehicle; venture; violate; volume; vowing; warns; year