OIG Issues Advisory Opinion for Disease Management Companies
 
September 20, 2002
 

On August 21, 2002, the Office of the Inspector General (OIG) issued OIG Advisory Opinion 02-12 concerning a proposed arrangement involving an Internet-based, chronic-disease-management company.  The company, which provides online drug and behavior compliance programs to members, requested guidance concerning (1) awarding points redeemable for goods and services to members and to physicians for undertaking compliance activities, (2) posting banner ads on the Web pages accessed by members and (3) providing links to participating pharmacies on Web pages accessed by members.  Citing many of the specific facts set forth by the company, the OIG stated that it would not impose administrative sanctions with regard to (1) the remuneration paid for these disease management services, (2) the awarding of points to members and physicians, (3) the banner ads or (4) the hyperlinks to participating pharmacies.  The OIG warned that Internet advertising, marketing relationships and "chat rooms" raise serious concerns and that this advisory opinion does not address the use or misuse of patient information for Internet marketing.  Any company interested in using some of these marketing techniques or instituting a similar awards program should carefully review the laws prohibiting inducements to beneficiaries as well as the anti-kickback statute. To view the entire opinion, go to http://oig.hhs.gov/fraud/docs/advisoryopinions/2002/ao0212.pdf