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ForwardOIG's First Food-as-Medicine Advisory Opinion: Key Compliance Lessons
On July 14, 2026, OIG published OIG Advisory Opinion 26-16, addressing a community health center's “food as medicine” program that provides eligible patients with produce boxes or healthy-food vouchers as part of a broader clinical intervention. OIG concluded that the arrangement implicates both the Anti-Kickback Statute and the Beneficiary Inducements CMP but declined to impose sanctions, citing the program's clinical objectives, financial-need criteria, limited scope, and compliance safeguards.
This advisory opinion appears to be the first published OIG advisory opinion directly addressing a provider-sponsored food-as-medicine program, making it a significant development for organizations seeking to integrate nutrition-based interventions into patient care strategies.
This webinar will analyze the opinion's key compliance considerations and explore its implications for health centers and other safety-net providers interested in developing or expanding food-as-medicine programs. Attendees will gain practical insights into the program features that OIG viewed favorably and the compliance safeguards that may help mitigate fraud-and-abuse risk in similar initiatives.
The on-demand version of this webinar will be available for purchase after the conclusion of the live webinar.
Target Audience
- Health center executives and leadership teams
- Compliance Officers and in-house counsel
- Clinical and population health leaders
- Grant program administrators
Learning Objectives
After this webinar, you will be able to:
- Describe OIG's application of the Federal Anti-Kickback Statute and Beneficiary Inducements CMP to a food-as-medicine program
- Identify the program characteristics that OIG viewed favorably in approving the favorable advisory opinion
- Apply strategies to mitigate legal risks in operating food-as-medicine programs
Adam J. Falcone
Adam Falcone is a Partner in the firm's national Health Care practice group, where he counsels a diverse spectrum of community-based organizations that render primary and behavioral health care services. Adam counsels clients on a wide range of health care issues, with a focus on fraud and abuse, reimbursement and payment and antitrust and competition matters. [Full Bio]
Participants can earn up to 1.20 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.
Attendee Requirements for CPE Credit
If you purchase CPE credit for this webinar you must satisfy the following conditions in order to receive your certificate:
- Answer at least 3 of the polling questions during the webinar
- Complete the evaluation survey after the conclusion of the webinar or in the follow-up email
Upon completion of these requirements, we will email you your CPE Certificate within two (2) weeks.
Additional Information
- Prerequisites: None
- Target Audience: Health center executives and leadership teams, Compliance officers and in-house counsel, Clinical and population health leaders, and Grant program administrators
- Advanced Preparation: None
- Program Level: All
- Delivery Method: Group Internet Based
Feldesman LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).
Available Credit
- 1.00 Certificate of Attendance
- 1.20 CPE
Price
Access to the recorded version of this webinar is included in your purchase.
You will have access to the recordings for 180 days after enrollment. Once posted to your account, you can view each webinar anytime on-demand during the access period identified in your purchase confirmation. For additional information on viewing and accessing webinars, view our full terms and conditions here.
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