Extract
Are 'Safe Harbors' Still Safe?
Summary
Action: The OIG recently issued an Advisory Opinion that "contractual" joint ventures are subject to prosecution even if they fully comply with all applicable safe harbors. Impact: OIG Advisory Opinions bind only the party(ies) seeking the opinion. However, this recent opinion provides valuable insight into the OIG's perspective on contractual joint ventures in particular, and the "protection" offered by the safe harbors generally. Effective Date: Dec...See the full content of this document
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