(Recorded Webinar) OIG's First Food-as-Medicine Advisory Opinion: Key Compliance Lessons
Register now to receive access to the recorded webinar on August 11, 2026. Live webinar registrants will automatically receive access to the recorded webinar.
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.
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]
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Available Credit
- 1.25 Certificate of Attendance
Price
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