News & Analysis as of September 18, 2024

Medicaid › Customer-Loyalty Programs

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Medicaid is a partnership program between states and the federal government to provide healthcare coverage for lower income individuals, people with disabilities, older people, and certain families with... more +

OIG’s First Advisory Opinion of 2022 Allows for Expansion of Discount Programs

Arnall Golden Gregory LLP on 2/15/2022

On January 19, 2022, the Department of Health and Human Services, Office of Inspector General (“OIG”) released a favorable advisory opinion, OIG Advisory Opinion No. 22-01 (the “Opinion”), analyzing a proposed expansion of...more

OIG Approves Customer Loyalty Program Involving Pharmacy Products

King & Spalding on 1/3/2020

On December 17, 2019, OIG published Advisory Opinion 19-06 approving a supermarket’s expansion of a loyalty program to allow customers to earn rewards points on out-of-pocket costs paid in connection with the purchase of...more

Health Update - August 2016

Manatt, Phelps & Phillips, LLP on 8/25/2016

Section 1332 Waivers: Will We See More State Innovation? - Editor's Note: In a new essay for the National Institute of Health Care Management (NIHCM), summarized below, Manatt Health examines Section 1332 waivers and the...more

First Circuit Affirms Dismissal For CVS Caremark Under Public Disclosure Bar

Dorsey & Whitney LLP on 7/8/2016

The FCA’s public disclosure bar precludes liability when a relator’s allegations have been publicly disclosed in a list of statutorily enumerated sources. Last week, the First Circuit added to the growing jurisprudence both...more

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Medicaid › Customer-Loyalty Programs

OIG’s First Advisory Opinion of 2022 Allows for Expansion of Discount Programs

OIG Approves Customer Loyalty Program Involving Pharmacy Products

Health Update - August 2016

First Circuit Affirms Dismissal For CVS Caremark Under Public Disclosure Bar

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