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 Opinion expands the existing “preventative care exception”, which permits incentives given to individuals to promote preventative care in specific circumstances, in that this Opinion allows the incentives even where the visits do not qualify as preventative care.

The OIG opinion can be found here.

We will be hosting a webinar addressing this issue, and other relevant FQHC updates including details on the 2021 O/OP Evaluation & Management Guidelines, and billing for Principal Care Management Services.

January 28, 2021 | 2:00 pm – 3:00 pm (EST)

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Should you have any questions regarding the above, please contact the Garfunkel Wild attorney with whom you regularly work, or contact us at

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