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Woman waiting in doctor's office According to OIG, the gift card incentive program would violate the federal anti-kickback statute because the $20 gift card would constitute remuneration intended to influence eligible patients. (Photo: Shutterstock)

On Dec. 23, 2020, the Department of Health and Human Services Office of the Inspector General (OIG) issued Advisory Opinion 20-08 approving an arrangement proposed by a federally qualified health center (FQHC) to offer gift cards to incentivize pediatric patients to attend rescheduled preventative and early intervention care appointments.

While gift cards themselves have been a topic of several advisory opinions in the past, this opinion offers insight as to how the OIG may distinguish acceptable inducements to support care from more problematic programs that offer beneficiary inducements merely as an incentive for patients to obtain federally reimbursable items and services.

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