OIG Revises Safe Harbors under the Anti-Kickback Statute and Civil Monetary Penalty Rules Regarding Beneficiary Inducements

On December 7, 2016, the Office of Inspector General of the US Department of Health and Human Services published a final rule containing revisions to both the federal Anti-Kickback Statute safe harbors and the beneficiary inducement prohibition in the civil monetary penalty rules. Effective January 6, 2017, the Final Rule modifies certain existing safe harbors and adds additional safe harbors to the Anti-Kickback Statute and incorporates Affordable Care Act-mandated exceptions into the definition of remuneration under the civil monetary penalty rules.

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Monica WallaceMonica Wallace
Monica A. Wallace focuses her practice on complex regulatory and transactional counseling to health care organizations, including health systems, hospitals, ambulatory surgery centers, physician groups, dental providers, integrated delivery systems, academic medical centers, DMEPOS and pharmaceutical manufacturers and suppliers, home health agencies, and venture capital and private equity firms and their health-related portfolio companies. Read Monica A. Wallace's full bio.


Joan PolacheckJoan Polacheck
Joan Polacheck advises clients on a variety of health care compliance and regulatory issues, including fraud and abuse, Stark law, Anti-Kickback Law and Medicare reimbursement issues. She represents a broad range of health care industry clients, including hospitals, suppliers, and drug and device companies. Read Joan Polacheck's full bio.


Brad DennisBrad Dennis
Brad Dennis advises health care clients on a broad spectrum of regulatory, corporate and transactional matters. He focuses on providing clients with clarity on a wide range of federal and state regulatory matters affecting hospitals and health systems, including physician contracting, compliance with the anti-kickback statute, Stark law, corporate practice of medicine, HIPAA, Medicare enrollment and reimbursement, and issues related to health care joint ventures. Read Bran Dennis' full bio.


Tiffany T. MasonTiffany T. Mason
Tiffany T. Mason maintains a broad health law practice, advising hospitals, health systems and health industry clients on regulatory compliance and transactional matters. Read Tiffany T. Mason's full bio.

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