Stakeholder requests for safe harbors from anti-kickback enforcement that would facilitate value-based payment arrangements are growing and involve a range of activities, such as patient adherence programs and product performance "warranties," according to reports from the US Department of Health and Human Services' Office of Inspector General (OIG).
Requests received are disclosed by the office in an appendix to its semi-annual report to Congress. The reports do not identify the requestors but do include OIG's response to the...
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