HHS-OIG Determines Consultant’s Gift Cards Given to Physicians Recommending Services Do Not Implicate Anti-Kickback Statute
Highlights
HHS-OIG released a favorable opinion allowing a consulting services company to offer gift cards to incentivize physician practices to recommend its services to other physicians
The agency determined the Anti-Kickback Statute would not be implicated
The arrangement would not involve referrals or purchases of any item or service for which payment may be made under a federal health care program
In late December, the U.S. Department of Health and Human Services’ Office of Inspector General (HHS-OIG) released Advisory Opinion No. 23-15, a favorable opinion regarding a proposed arrangement in which a company providing consulting services to physician practices would provide gift card incentives to the practices that recommend the company’s services to other physicians.
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