News & Analysis as of

Incentives CMP Waivers

McDermott Will & Emery

OIG Issues AO on Providing Gift Cards for Completed Colon Cancer Screening Tests

McDermott Will & Emery on

The US Department of Health and Human Services Office of Inspector General (OIG) recently issued Advisory Opinion (AO) 23-03, analyzing a proposed arrangement in which a company that manufactures an at-home colon cancer...more

King & Spalding

OIG Issues Favorable Advisory Opinion Regarding Laboratory Arrangement to Offer Discounts

King & Spalding on

On March 29, 2023, OIG posted Advisory Opinion No. 23-03 regarding a laboratory’s proposed arrangement to provide a prepaid card of up to $75 to encourage individuals to return the sample collection kit associated with the...more

Bass, Berry & Sims PLC

OIG Approves Gift Cards to Promote Patient Compliance with a Preventive Screening Measure

The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued Advisory Opinion 23-03, approving a proposal by the manufacturer of a colorectal cancer screening test and its wholly owned...more

Baker Donelson

Limited Modifications in Final ACO Fraud and Abuse Waivers Most Notably Include Cut of Gainsharing CMP Waiver

Baker Donelson on

Nearly four years after publishing their joint interim final rule with comment period, effective November 2, 2011 (IFC), the OIG and CMS (Agencies) have finalized the waivers of various fraud and abuse laws in the context of...more

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