Alerts1.8.26
HHS-OIG Issues Favorable Opinion on Vaccine Manufacturer Offering Upfront Discounts and Rebates to Customers for Vaccines

Highlights
- The proposed arrangement included safeguards, HHS-OIG said, that limited risk under the Anti-Kickback Statute and accordingly did not warrant sanctions.
- It also did not require customers to purchase services from the manufacturer and did not pose a risk of patient steering to the manufacturer’s vaccines.
The U.S. Department of Health and Human Services’ Office of Inspector General (HHS-OIG) recently released Advisory Opinion No. 25-11, a favorable opinion regarding the federal Anti-Kickback Statute (AKS) as applied to a biopharmaceutical manufacturer that manufacturers certain vaccines offering discounts and rebates on vaccines reimbursable under federal health care programs to its customers.
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