New OIG Opinion Permits FQHC to Offer Gift Cards to Patients

January 6, 2021

The Office of Inspector General (“OIG”) posted OIG Advisory Opinion 20-08 on Tuesday, December 30, 2020. The Opinion permits an FQHC to offer $20 gift cards to incentivize pediatric patients who have missed two (2) or more previously scheduled preventative and early intervention care appointments within the previous six (6) months. We note that this …

OIG Issues Important New And Revised Safe Harbors Under The Federal Anti-Kickback Statute – Part 2

December 21, 2020

  As we previously reported, the United States Department of Health and Human Services Office of Inspector General (“OIG”) recently issued an important final rule (the “Final Rule”) that makes significant changes to existing “Safe Harbors” under the Federal Anti-kickback Statue (“AKS”) and that adds new Safe Harbors that provide protection from AKS sanctions for …

OIG Issues Important New And Revised Safe Harbors

December 11, 2020

The United States Department of Health and Human Services (“HHS”), Office of Inspector General (“OIG”) recently issued an important final rule (the “Final Rule”) that makes significant changes to existing “Safe Harbors” under the Federal Anti-kickback Statue (“AKS”) and that adds new Safe Harbors that provide protection from AKS sanctions for certain types of arrangements.  …

CMS Adopts Important Changes To The Stark Regulations

  On December 2, 2020, the Centers for Medicare and Medicaid Services (CMS) issued a Final Rule that includes important changes to the federal physician self-referral law, commonly referred to as the “Stark Law.”  In general, the Stark Law prohibits a physician from making a referral for certain “designated health services” (DHS) to an entity …

OIG Issues Special Fraud Alert Reiterating Concerns Regarding Speaker Programs

November 30, 2020

  On November 16, 2020, the U.S. Department of Health and Human Services, Office of the Inspector General (the “OIG”) issued a Special Fraud Alert (“SFA”) emphasizing the fraud and abuse risks inherent in speaker programs run by pharmaceutical and medical device companies. The SFA specifically focuses on pharmaceutical and medical device company-sponsored events at …