No Sanctions: Anti-Fraud Safeguards Protect Medical Supply Distributor’s Customer Loyalty Program
Highlights
The HHS-OIG released a favorable opinion regarding a customer loyalty program in which members earn redeemable points for future product purchases and tiered benefits by purchasing company products
The “discount” safe harbor to the Anti-Kickback Statute (AKS) does not apply to the proposed arrangement’s loyalty program
The proposed arrangement includes factors, the agency said, that limit risk under the AKS and the civil monetary penalty laws (CMP)
The U.S. Department of Health and Human Services’ Office of Inspector General (HHS-OIG) recently released Advisory Opinion No. 24-10, a favorable opinion regarding the federal Anti-Kickback Statute (AKS) and civil monetary penalty laws (CMP) against beneficiary inducements as applied to a customer loyalty program.
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