Advisory Opinion 01-19
Concerning a hospital's proposed donation of free office space to an entity that provides free end-of-life services to patients with terminal illnesses. Specifically, whether that donation would constitute grounds for the imposition of sanctions under the exclusion authority at section 1128(b)(7) of the Social Security Act (the "Act") or the civil monetary penalty provision at section 1128A(a)(7) of the Act, as those sections relate to the commission of acts described in section 1128B(b) of the Act.