OIG Advisory Bulletin – Contractual Joint Ventures

Office of Inspector General
Special Advisory Bulletin

Contractual Joint Ventures

Introduction

This Special Advisory Bulletin addresses certain complex contractual arrangements for the provision of items and services previously identified as suspect in our 1989 Special Fraud Alert on Joint Venture Arrangements. While much of the discussion in the 1989 Special Fraud Alert focused on investor referrals to newly formed entities, we observed that:

The Office of Inspector General has become aware of a proliferation of arrangements between those in a position to refer business, such as physicians, and those providing items or services for which Medicare or Medicaid pays. Some . . .