(Recorded Webinar) Sunset of the OIG’s Informal Guidance During COVID: What Can Health Centers Do to Continue Certain Activities after the PHE Expires?

This webinar is part three of the six-part "Preparing for the End of the Federal PHE" webinar series. To view and/or purchase the full series, click here.

Duration: 50 minutes
Recorded on: 12/6/2022

During the COVID-19 Public Health Emergency (PHE), the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued informal guidance approving activities that would normally run afoul of the federal Anti-Kickback Statute and Civil Monetary Penalty (CMP) provision prohibiting inducements to beneficiaries. For example, the OIG’s guidance approved health centers offering cash incentives to patients who receive COVID-19 vaccinations, providing free COVID-19 diagnostic testing, and offering emergency cash assistance to financially needy individuals. Because the informal guidance only applies to arrangements during the PHE, health centers that wish to continue offering incentives or cash assistance will need to modify these arrangements to comply with existing exceptions or request formal approval by the OIG through its advisory opinion process. 

Target Audience

  • C-Suite
  • Compliance Officers and Professionals
  • Population Health and Quality Improvement Staff 

Learning Objectives

After this webinar, you will be able to:

  • Understand how certain activities implicate the federal Anti-Kickback Statute and Civil Monetary Penalty (CMP) provision prohibiting inducements to beneficiaries
  • Identify key factors in the OIG’s analysis when approving activities in informal guidance during the PHE
  • Describe options for continuing activities after the PHE expires without the protection of the informal guidance
Course summary
Available credit: 
  • 1.00 Certificate of Attendance
Course opens: 
Course expires: 


Adam J. Falcone is a Partner in the firm's national health law practice group, where he counsels a diverse spectrum of community-based organizations that render primary and behavioral healthcare services. Adam counsels clients on a wide range of health law issues, with a focus on fraud and abuse, reimbursement and payment, and antitrust and competition matters. [Full Bio]

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Available Credit

  • 1.00 Certificate of Attendance


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This webinar is part three of the six-part "Preparing for the End of the Federal PHE" webinar series. To view and/or purchase the full series, click here.


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