Management service organizations (MSOs) with affiliated clinical labs and urgent care clinics should take note of newly identified guardrails that will facilitate their compliance with the federal Anti-Kickback Statute (AKS). Earlier this year, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion No. 26-02, a favorable opinion concluding that an MSO could own and operate an independent clinical laboratory that accepts referrals from urgent care centers managed by the same MSO without implicating the AKS.
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