What OIG’s Removal of a Frequently Cited Basis for Rejecting Advisory Opinion Requests Means for the Government and for Requestors
This Featured Article is contributed by AHLA's Fraud and Abuse Practice Group.
- January 28, 2022
- Jennifer Michael , Bass Berry & Sims PLC
On January 11, 2022, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) published a final rule removing one of the most frequently cited bases for rejecting advisory opinion requests.[1] Specifically, OIG amended the regulations governing the agency’s advisory opinion process to remove the provision that requires OIG to reject advisory opinion requests when “the same or substantially the same course of action is under investigation or has been the subject of a proceeding involving HHS or another governmental agency.”
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