For the second time, the HHS Office of Inspector General has issued a confusing advisory opinion on payment of transcription costs by radiologists, concluding once again that such a financial arrangement would not violate the federal anti-kickback statute. OIG Advisory Opinion No. 15-15 relates to a proposed arrangement in which a hospital would bill a radiology group for transcription of the radiology group’s reports for patients who are not hospital patients, but rather patients of a third-party clinic which purchases the technical component of radiology services from the hospital for its patients.

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