Robinson Cole LLP
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Danielle H. Tangorre has extensive experience counseling clinical laboratories, health care providers, behavioral health providers, hospitals, and other healthcare entities to navigate operational and compliance issues and assist with business transactions. Danielle takes a holistic approach to help her clients achieve their business goals within the regulatory maze of federal and state laws. In addition, Danielle regularly advises clinical laboratories and other health care entities with respect to federal and state fraud and abuse laws and represents clients before federal and state agencies related to payment disputes and investigations.

Danielle’s work with clients involves:

Compliance, Operational + Regulatory Matters

Danielle advises clients on operational and compliance issues, federal and state fraud and abuse laws, including the Stark law, Anti-Kickback Statute and the Eliminating Kickbacks in Recovery Act (as well as state law counterparts), the HIPAA (Health Insurance Portability and Accountability Act of 1996), corporate practice of medicine, reimbursement and billing compliance, and other regulatory matters.

As a result of her clinical ethics fellowship at the Alden March Bioethics Institute at Albany Medical Center, Danielle provides her clients with an uncommon, holistic perspective. With her experience in ethics and day-to-day experience in delivering care in the hospital, Danielle actively engages with and advises clients on the ethical and legal requirements related to delivery of health care services, consent issues, guardianship, and other advanced care planning.

Transactional

Danielle has experience representing health care providers with the buying and selling of practices, structuring transactions, joint ventures, and partnerships and conducting healthcare due diligence. She has counseled several health care providers through complex re-organizations and affiliations while navigating various business and healthcare regulatory concerns. Danielle also routinely advises clients on how to navigate complex federal and state laws and obtain required state consents.

Government Investigations

Danielle assists in conducting internal investigations and conducting the healthcare analysis as it relates to governmental inquiries conducted by the Centers for Medicare and Medicaid, state Medicaid Fraud Control units, the Office of Inspector General and the United States Department of Justice, as well as other state regulatory agencies.

Community Involvement

Danielle serves on the Board of Directors of the Ronald McDonald House of Charities of the Capital Region. She is also an Adjunct Professor at Albany Law School and an Assistant Adjunct Professor at Albany Medical Center. She was also previously a member of Albany Medical Center’s Institutional Review Board. Danielle also serves on the Advisory Board for the Government Law Center of Albany Law School.

  • Albany Law School of Union University (Juris Doctor)
  • Albany Medical School (Masters)
    • Bioethics
  • University of Virginia (Bachelors)
    • B.A., Political Philosophy, Policy and Law

  • State of New York
  • U.S. District Court, Eastern District of New York
  • U.S. District Court, Northern District of New York
  • U.S. District Court, Southern District of New York

Selected by her peers for inclusion in The Best Lawyers in America© in the areas of Administrative / Regulatory Law, Elder Law, and Health Care Law for 2026

Listed as a Future Star in Benchmark Litigation for 2026 and 2025

Selected as a Rising Star to the New York - Upstate Super Lawyers list from 2015 to 2025

Selected by her peers for inclusion in the Best Lawyers: Ones to Watch in the areas of Administrative / Regulatory Law, Elder Law, and Health Care Law from 2021 to 2025

Albany Law School
Advisory Board Member of the Government Law Center

New York State Bar Association

Albany County Bar Association

American Health Lawyers Association

Ronald McDonald House of the Capital Region
Secretary 
 

Publications


OIG Reiterates a Core Message: Stark Compliance and Fair Market Value Alone Do Not Shield Against Anti-Kickback Statute Risk teaser
April 24, 2026

OIG Reiterates a Core Message: Stark Compliance and Fair Market Value Alone Do Not Shield Against Anti-Kickback Statute Risk

Health Law Diagnosis
Legal Update: DOJ Announces First False Claims Act Settlement for “Illegal DEI Practices” teaser
April 14, 2026

Legal Update: DOJ Announces First False Claims Act Settlement for “Illegal DEI Practices”

Continuing Appropriations Act, 2026: Another Lifeline for Medicare Telehealth Flexibilities teaser
February 4, 2026

Continuing Appropriations Act, 2026: Another Lifeline for Medicare Telehealth Flexibilities

Health Law Diagnosis
OIG Reiterates a Core Message: Stark Compliance and Fair Market Value Alone Do Not Shield Against Anti-Kickback Statute Risk teaser
April 24, 2026

OIG Reiterates a Core Message: Stark Compliance and Fair Market Value Alone Do Not Shield Against Anti-Kickback Statute Risk

Health Law Diagnosis
Legal Update: DOJ Announces First False Claims Act Settlement for “Illegal DEI Practices” teaser
April 14, 2026

Legal Update: DOJ Announces First False Claims Act Settlement for “Illegal DEI Practices”

Continuing Appropriations Act, 2026: Another Lifeline for Medicare Telehealth Flexibilities teaser
February 4, 2026

Continuing Appropriations Act, 2026: Another Lifeline for Medicare Telehealth Flexibilities

Health Law Diagnosis
New Year Brings Old Obligations with a Recent Twist: PAMA Reporting is Back teaser
February 3, 2026

New Year Brings Old Obligations with a Recent Twist: PAMA Reporting is Back

The ColLABorative Brief
Medicare Part B Lab Spending Increased in 2024: Here’s what the Latest OIG Report Reveals teaser
February 2, 2026

Medicare Part B Lab Spending Increased in 2024: Here’s what the Latest OIG Report Reveals

The ColLABorative Brief
Eliminating Kickbacks in Recovery Act – 2025 Updates and Looking to 2026 teaser
February 2, 2026

Eliminating Kickbacks in Recovery Act – 2025 Updates and Looking to 2026

The ColLABorative Brief
DOJ Enforcement of Clinical Laboratories: Trends from Q4 2025 teaser
February 2, 2026

DOJ Enforcement of Clinical Laboratories: Trends from Q4 2025

The ColLABorative Brief
Song Remains the Same – Medicare Telehealth Services At Risk of Expiring Again on January 30, 2026 teaser
January 29, 2026

Song Remains the Same – Medicare Telehealth Services At Risk of Expiring Again on January 30, 2026

Health Law Diagnosis
South Carolina Lab Settles False Claim Act Case – A Study on Commercial Reasonableness and Disguised Kickbacks teaser
January 12, 2026

South Carolina Lab Settles False Claim Act Case – A Study on Commercial Reasonableness and Disguised Kickbacks

Health Law Diagnosis


New Year Brings Old Obligations with a Recent Twist: PAMA Reporting is Back teaser
February 3, 2026

New Year Brings Old Obligations with a Recent Twist: PAMA Reporting is Back

The ColLABorative Brief
Medicare Part B Lab Spending Increased in 2024: Here’s what the Latest OIG Report Reveals teaser
February 2, 2026

Medicare Part B Lab Spending Increased in 2024: Here’s what the Latest OIG Report Reveals

The ColLABorative Brief
Eliminating Kickbacks in Recovery Act – 2025 Updates and Looking to 2026 teaser
February 2, 2026

Eliminating Kickbacks in Recovery Act – 2025 Updates and Looking to 2026

The ColLABorative Brief
DOJ Enforcement of Clinical Laboratories: Trends from Q4 2025 teaser
February 2, 2026

DOJ Enforcement of Clinical Laboratories: Trends from Q4 2025

The ColLABorative Brief
Song Remains the Same – Medicare Telehealth Services At Risk of Expiring Again on January 30, 2026 teaser
January 29, 2026

Song Remains the Same – Medicare Telehealth Services At Risk of Expiring Again on January 30, 2026

Health Law Diagnosis
South Carolina Lab Settles False Claim Act Case – A Study on Commercial Reasonableness and Disguised Kickbacks teaser
January 12, 2026

South Carolina Lab Settles False Claim Act Case – A Study on Commercial Reasonableness and Disguised Kickbacks

Health Law Diagnosis

News


April 22, 2026

Danielle Tangorre Explains Significance of Groundbreaking Decision for Clinical Laboratories

Health Care Enforcement + False Claims Act Litigation team member Danielle Tangorre spoke with The Dark Report and G2 Intelligence about the significance of the U.S. Court of Appeals for the First Circuit  in U.S. ex rel OMNI Healthcare v. MD Spine Solutions LLC, et al that came down in December 2025. The decision affirmed a lower court’s dismissal of a “high stakes” False Claims Act lawsuit, providing clarity for the diagnostic laboratory industry. Danielle, along with team members Edward J. Heath and Seth B. Orkand, represented MD Labs in the appeals case. Covering the decision from a legal risk perspective, The Dark Report said, “this decision creates a new 'safe harbor' for medical necessity while defining the specific boundaries where that protection ends.” Danielle explained the decision enshrined that “clinical laboratories can generally rely on a physician’s order as evidence that testing is reasonable and necessary…[T]hat’s significant because labs bill for tests but do not treat patients. They rely on the physician’s clinical judgment.” Danielle noted, however, that the relationship is collaborative and labs also have a corollary duty. Danielle also highlighted how the decision shifted the burden of proof, as the First Circuit Court focused specifically on the intent required for a lab to be held liable for fraud. “The court also clarified that if a lab relies on a physician’s order, the burden shifts to the relator to show the lab should not have relied on it—for example, if the lab influenced or usurped the physician’s decision-making,” said Tangorre. “That’s a major takeaway for laboratories.” Because Circuit Court rulings are often cited by other courts across the country, the decision provides a defensive blueprint for labs facing similar allegations. The decision “provides clarity on how courts view a lab’s role in certifying medical necessity while relying on physicians,” Danielle said.  “It essentially gives labs guardrails: Labs can rely on physician orders, but here’s where you can run into trouble. Organizations that operate cohesively and not in silos are in the best position to manage risk,” Danielle concluded. G2 Intelligence’s "Lab Industry Advisor,” another leading publication for the clinical lab industry examined the decision by focusing on compliance elements of the case. The article said a practical takeaway from the case for clinical lab directors involves the design of test requisition forms. “The courts emphasized that MD Labs did not improperly design its requisition. That’s an important lesson. Labs need to ensure requisitions are not steering or influencing test selection,” Danielle warned. “The same applies to marketing. Overpromising test value or implying broader clinical utility than supported can create risk, even if labs can generally rely on physician orders.” While the appellate ruling focused on medical necessity, it allowed the lower court’s findings on independent contractor commissions to stand. The clinical lab industry has long assumed that paying commissions to independent sales agents is “per se” violation of the Anti-Kickback Statue or the Eliminating Kickbacks in Recovery Act. The MD Labs case suggests that context and compliance matter most. “Importantly, the relator did not appeal the independent contractor issue, so the finding that commission payments are not inherently illegal stands,” Danielle pointed out. “That aligns with a growing trend in the courts: Sales commissions are not automatically violations of AKS or EKRA unless there is some additional improper conduct—what I call a ‘plus factor’—such as influencing ordering behavior.” The court was persuaded by the fact that MD Labs had a robust compliance framework, Danielle said. “Independent contractors were treated similarly to employees, and compliance oversight was robust,” she added. “That’s critical.”

Dark Report
G2 Intelligence’s Lab Industry Advisor
March 23, 2026

Danielle Tangorre Discusses Pathology Arrangement Scrutiny in Healthcare

​​​​​​​AHLA's “Speaking of Health Law” Podcast
December 18, 2025

Business Transactions in Health Care Team Wins “Pharma & Devices Deal of the Year” at Global M&A Network’s 7th Annual USA Middle Markets M&A Atlas Awards Gala

Global M&A Network
Business Transactions in Health Care Team Wins “Pharma & Devices Deal of the Year” at Global M&A Network’s 7th Annual USA Middle Markets M&A Atlas Awards Gala teaser
April 22, 2026

Danielle Tangorre Explains Significance of Groundbreaking Decision for Clinical Laboratories

Health Care Enforcement + False Claims Act Litigation team member Danielle Tangorre spoke with The Dark Report and G2 Intelligence about the significance of the U.S. Court of Appeals for the First Circuit  in U.S. ex rel OMNI Healthcare v. MD Spine Solutions LLC, et al that came down in December 2025. The decision affirmed a lower court’s dismissal of a “high stakes” False Claims Act lawsuit, providing clarity for the diagnostic laboratory industry. Danielle, along with team members Edward J. Heath and Seth B. Orkand, represented MD Labs in the appeals case. Covering the decision from a legal risk perspective, The Dark Report said, “this decision creates a new 'safe harbor' for medical necessity while defining the specific boundaries where that protection ends.” Danielle explained the decision enshrined that “clinical laboratories can generally rely on a physician’s order as evidence that testing is reasonable and necessary…[T]hat’s significant because labs bill for tests but do not treat patients. They rely on the physician’s clinical judgment.” Danielle noted, however, that the relationship is collaborative and labs also have a corollary duty. Danielle also highlighted how the decision shifted the burden of proof, as the First Circuit Court focused specifically on the intent required for a lab to be held liable for fraud. “The court also clarified that if a lab relies on a physician’s order, the burden shifts to the relator to show the lab should not have relied on it—for example, if the lab influenced or usurped the physician’s decision-making,” said Tangorre. “That’s a major takeaway for laboratories.” Because Circuit Court rulings are often cited by other courts across the country, the decision provides a defensive blueprint for labs facing similar allegations. The decision “provides clarity on how courts view a lab’s role in certifying medical necessity while relying on physicians,” Danielle said.  “It essentially gives labs guardrails: Labs can rely on physician orders, but here’s where you can run into trouble. Organizations that operate cohesively and not in silos are in the best position to manage risk,” Danielle concluded. G2 Intelligence’s "Lab Industry Advisor,” another leading publication for the clinical lab industry examined the decision by focusing on compliance elements of the case. The article said a practical takeaway from the case for clinical lab directors involves the design of test requisition forms. “The courts emphasized that MD Labs did not improperly design its requisition. That’s an important lesson. Labs need to ensure requisitions are not steering or influencing test selection,” Danielle warned. “The same applies to marketing. Overpromising test value or implying broader clinical utility than supported can create risk, even if labs can generally rely on physician orders.” While the appellate ruling focused on medical necessity, it allowed the lower court’s findings on independent contractor commissions to stand. The clinical lab industry has long assumed that paying commissions to independent sales agents is “per se” violation of the Anti-Kickback Statue or the Eliminating Kickbacks in Recovery Act. The MD Labs case suggests that context and compliance matter most. “Importantly, the relator did not appeal the independent contractor issue, so the finding that commission payments are not inherently illegal stands,” Danielle pointed out. “That aligns with a growing trend in the courts: Sales commissions are not automatically violations of AKS or EKRA unless there is some additional improper conduct—what I call a ‘plus factor’—such as influencing ordering behavior.” The court was persuaded by the fact that MD Labs had a robust compliance framework, Danielle said. “Independent contractors were treated similarly to employees, and compliance oversight was robust,” she added. “That’s critical.”

Dark Report
G2 Intelligence’s Lab Industry Advisor
March 23, 2026

Danielle Tangorre Discusses Pathology Arrangement Scrutiny in Healthcare

​​​​​​​AHLA's “Speaking of Health Law” Podcast
December 18, 2025

Business Transactions in Health Care Team Wins “Pharma & Devices Deal of the Year” at Global M&A Network’s 7th Annual USA Middle Markets M&A Atlas Awards Gala

Global M&A Network
Business Transactions in Health Care Team Wins “Pharma & Devices Deal of the Year” at Global M&A Network’s 7th Annual USA Middle Markets M&A Atlas Awards Gala teaser
December 4, 2025

Health Care Enforcement Team Secures First Circuit Win for Clinical Lab in False Claims Act Appeal

November 12, 2025

Danielle Tangorre Shares 2026 Predictions Citing AI, Audits and Increased Enforcement Facing Clinical Labs

G2 Intelligence
November 6, 2025

Robinson+Cole Commends 62 Attorneys Recognized in 2025 Super Lawyers®

Recognition spans key regions and highlights the firm’s seasoned practitioners and emerging leaders in many business transactions and litigation practices
Robinson+Cole Commends 62 Attorneys Recognized in 2025 <i>Super Lawyers</i>® teaser
October 20, 2025

Conor Duffy and Danielle Tangorre Author Article on Expiration of COVID-Era Telehealth Policies amid Government Shutdown

Law360 Expert Analysis
October 8, 2025

Robinson+Cole Healthcare Transactions Team Represents The Pennant Group in One of 2025’s Largest Homecare and Hospice Transactions

August 28, 2025

Danielle Tangorre Discusses Lessons Learned From the Recent $14.6 Billion Healthcare Fraud Takedown

G2 Intelligence

December 4, 2025

Health Care Enforcement Team Secures First Circuit Win for Clinical Lab in False Claims Act Appeal

November 12, 2025

Danielle Tangorre Shares 2026 Predictions Citing AI, Audits and Increased Enforcement Facing Clinical Labs

G2 Intelligence
November 6, 2025

Robinson+Cole Commends 62 Attorneys Recognized in 2025 Super Lawyers®

Recognition spans key regions and highlights the firm’s seasoned practitioners and emerging leaders in many business transactions and litigation practices
Robinson+Cole Commends 62 Attorneys Recognized in 2025 <i>Super Lawyers</i>® teaser
October 20, 2025

Conor Duffy and Danielle Tangorre Author Article on Expiration of COVID-Era Telehealth Policies amid Government Shutdown

Law360 Expert Analysis
October 8, 2025

Robinson+Cole Healthcare Transactions Team Represents The Pennant Group in One of 2025’s Largest Homecare and Hospice Transactions

August 28, 2025

Danielle Tangorre Discusses Lessons Learned From the Recent $14.6 Billion Healthcare Fraud Takedown

G2 Intelligence

Events


Past

Redefining Audit Preparedness & Compliance for Future-Proof Payments

May 14 2026
Q1 Productions’ 33rd Tri-Annual Diagnostic Coverage & Reimbursement Conference
Past

The Slippery Slope to Enforcement: How Payor Audits Trigger Government Action—and How to Identify Compliance Risk Early

Apr 28 2026
2026 Executive War College
Past

Redefining Audit Preparedness & Compliance for Future-Proof Payments

May 14 2026
Q1 Productions’ 33rd Tri-Annual Diagnostic Coverage & Reimbursement Conference
Past

The Slippery Slope to Enforcement: How Payor Audits Trigger Government Action—and How to Identify Compliance Risk Early

Apr 28 2026
2026 Executive War College
Past

Under OIG Scrutiny: Translating 2025 Enforcement Trends Into Actionable Strategies for Laboratory Compliance, Test Utilization Optimization, and Enterprise-Wide Risk Mitigation in 2026

Apr 28 2026
2026 Executive War College
Past

Lab Compliance and Test Utilization: Prepare for 2026 and Beyond

Mar 25 2026
Whitehat Communications’ Point of Care Group Webinar Series
Past

Redefining Audit Preparedness & Compliance for Future-Proof Payments

Mar 18 2026
Q1 Productions’ 32nd Tri-Annual Diagnostic Coverage & Reimbursement Conference
Past

KnowledgeBridge: Proactive Approaches to Compliance: A Preventative Checkup

Jan 29 2026
Consero Healthcare Chief Ethics & Compliance Officer Forum
Past

Under OIG Scrutiny: Translating 2025 Enforcement Trends Into Actionable Strategies for Laboratory Compliance, Test Utilization Optimization, and Enterprise-Wide Risk Mitigation in 2026

Apr 28 2026
2026 Executive War College
Past

Lab Compliance and Test Utilization: Prepare for 2026 and Beyond

Mar 25 2026
Whitehat Communications’ Point of Care Group Webinar Series
Past

Redefining Audit Preparedness & Compliance for Future-Proof Payments

Mar 18 2026
Q1 Productions’ 32nd Tri-Annual Diagnostic Coverage & Reimbursement Conference
Past

KnowledgeBridge: Proactive Approaches to Compliance: A Preventative Checkup

Jan 29 2026
Consero Healthcare Chief Ethics & Compliance Officer Forum

Health Law Diagnosis Blog


Below is an excerpt of the Health Law Diagnosis blog posts authored by Danielle.

OIG Reiterates a Core Message: Stark Compliance and Fair Market Value Alone Do Not Shield Against Anti-Kickback Statute Risk

On April 23, 2026, the HHS Office of Inspector General (OIG) quietly—but pointedly—added two new FAQs to its “General Questions Regarding Certain Fraud and Abuse Authorities.” Although the principles articulated are not new, the timing and clarity of these FAQs reflect OIG’s continued effort to correct common—and risky—misunderstandings in the health care industry regarding the... Continue Reading

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Continuing Appropriations Act, 2026: Another Lifeline for Medicare Telehealth Flexibilities

This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law. On February 3, 2026, President Trump signed HR 7148, the Consolidated Appropriations Act, 2026 (“the Act”) ending the 4-day partial government shutdown. The Act, part of a broader fiscal year (FY) 2026 spending package, includes a further... Continue Reading

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New Year Brings Old Obligations with a Recent Twist: PAMA Reporting is Back

After uncertainty over the last few months, the last few weeks saw potential changes to the Protecting Access to Medicare Act of 2014 (PAMA) under section 6226 of the Consolidated Appropriations Act of 2026. On January 20, 2026, the House Appropriations Committee released the Consolidated Appropriations Act 2026, which included several healthcare extenders, among them... Continue Reading

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Medicare Part B Lab Spending Increased in 2024: Here’s what the Latest OIG Report Reveals

This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law. Introduction On January 28, 2026, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released a new report analyzing Medicare Part B (Part B) spending on laboratory tests in 2024. The Protecting Access... Continue Reading

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Eliminating Kickbacks in Recovery Act – 2025 Updates and Looking to 2026

The Eliminating Kickbacks in Recovery Act (EKRA), enacted in 2018 as part of the SUPPORT Act, established a criminal statute prohibiting payments for patient referrals related to recovery homes, clinical treatment facilities, and laboratories. EKRA mostly mirrors the Anti-Kickback Statute (AKS) but extends its reach to commercial health insurance as well as federal programs like... Continue Reading

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DOJ Enforcement of Clinical Laboratories: Trends from Q4 2025

This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law. The final quarter of 2025 saw continued enforcement actions against clinical labs and other related healthcare entities. The Office of Inspector General (OIG) and Department of Justice (DOJ) heavily focused on False Claims Act (FCA) violations, Anti-Kickback... Continue Reading

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Song Remains the Same – Medicare Telehealth Services At Risk of Expiring Again on January 30, 2026

Healthcare providers are currently facing yet another termination of Medicare telehealth flexibilities at the end of the day on January 30, 2026, unless Congress acts on proposals to further extend the COVID-era flexibilities for telehealth. If no legislative action is taken before January 30, 2026, the providers and Medicare patients who have depended on expanded... Continue Reading

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South Carolina Lab Settles False Claim Act Case – A Study on Commercial Reasonableness and Disguised Kickbacks

A clinical lab in Anderson, South Carolina, and its founder and CEO have agreed to pay a minimum of $6.8 million to settle a federal qui tam case based on allegations for paying illegal kickbacks to physicians in exchange for referrals of laboratory tests. Under the settlement agreement, this figure may increase to approximately $10.1... Continue Reading

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Update on Processing of Telehealth Claims Impacted During the Government Shutdown

The recent government shutdown caused multiple Medicare statutory payment provisions to lapse on October 1, 2025, due to the absence of Congressional action. With the passage of the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026 (Pub. L. 119-37), (discussed here), Congress has retroactively restored many of these provisions.... Continue Reading

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OIG Greenlights Sponsored Diagnostic Testing in Advisory Opinion 25-07

This post is co-authored with Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law. On July 2, 2025, the Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 25-07, which concluded that a pharmaceutical manufacturer’s proposed arrangement to sponsor a free, FDA-approved companion diagnostic test for eligible... Continue Reading

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