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Baker & Hostetler LLP | USA | 14 Apr 2011

Joint venture company advisory opinion

The U.S. Department of Health and Human Services (HHS) OIG on April 7 issued OIG Advisory Opinion No. 11-03, in which it concluded that the formation and operation of a new long-term care pharmacy to be owned by an employee of a sponsoring long-term care pharmacy along with long-term care facility owners could potentially constitute a kickback.

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