Tag Archives: safe harbors

Recent Developments on the Fair Market Value Front – Part 1

Over the last several months, a handful of federal court decisions—including two rulings this summer on challenges to the admissibility of proposed expert testimony—serve as reminders of the importance of (and parameters around) fair market value (FMV) issues in the context of the Anti-Kickback Statute (AKS) and the False Claims Act (FCA). First, a quick … Continue Reading

OIG Seeks Suggestions for New Anti-Kickback Safe Harbors and Special Fraud Alerts

On December 30, 2014, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) published a request for public comment in the Federal Register, soliciting suggestions for new safe harbors – or exceptions – to the Anti-Kickback Statute (AKS) and Special Fraud Alerts – statements from OIG that give guidance to providers … Continue Reading