Owners of ambulatory surgical centers (ASCs) often wish to receive a share of the professional fees paid to their anesthesiologists and nurse anesthetists.  ASC owners and anesthesiologists and CRNAs have adopted—or at least proposed—numerous corporate and contractual structures over the last few decades to accomplish this transfer of revenues.  The federal Anti-Kickback Statute (AKS), which prohibits a broad range of payments for referrals, has generally caused conservative lawyers to advise against such arrangements.  Some attorneys and other advisors who are less risk-averse have helped their clients to go ahead. The HHS Office of the Inspector General (OIG) has just provided some guidance on the issue.  The guidance takes the form of an Advisory Opinion (No. 12-06) (posted June 1, 2012), which means that the decision is not binding on any parties, including the OIG.  Nevertheless, the Advisory Opinion spells out how the OIG would apply the AKS principles to two common...