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THE ABA HE ALTH L AW SECTION HEALTH LAWYER THE IN THIS ISSUE Volume 12, Number 3 February 2000 Navigating the New Safe Harbors to the Anti-Kickback Statute......................................1 National Labor Relations Board Rules that Interns and Residents May Unionize...........................18 Office of Inspector General’s Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs ........................21 The Hazards of a Speedy Pay Discount...

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