2024 U.S. Health Care Fraud, Waste & Abuse Trends (Part I): Advisory Opinions on Patient Inducements

RopesTalk

Join Ropes & Gray’s attorneys for a three-part podcast series exploring recent regulatory, compliance, and enforcement developments in the fraud, waste, and abuse space and the potential implications for health care and life science companies in 2024. In this first installment, health care partners Devin Cohen and Michael Lampert discuss key considerations for understanding recent advisory opinions published by the U.S. Department of Health and Human Services (“HHS”) Office of the Inspector General (“OIG”), as well as their scope and implications. With particular focus on advisory opinions concerning beneficiary inducements to patients, this episode examines Anti-Kickback Statute and Civil Monetary Penalties Law concerns with such arrangements, as well as factors OIG has deemed to alleviate such concerns in the advisory opinions it issued in the past year.