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  • Alex Lipovtsev

US Office of Inspector General Provides COVID-19-related FAQs

In response to the COVID-19 public health emergency, the Office of Inspector General (OIG) periodically publishes FAQs from the health care community. The FAQs provide guidance “…regarding the application of OIG’s administrative enforcement authorities, including the Federal anti-kickback statute [AKS] and civil monetary provision prohibiting inducements to beneficiaries (Beneficiary Inducements CMP)” during the COVID-19 outbreak. Under normal circumstances, each factual scenario addressed by OIG’s FAQs would implicate the AKS and/or Beneficiary Inducements CMP. However, through its FAQs and considering the COVID-19 public health emergency, OIG has reported that it views the subject scenarios as presenting a “…low risk of fraud or abuse,” provided certain conditions are met. Among these conditions is the requirement that the subject’s goods or services are only available prior to the termination of the COVID-19 public health emergency declaration.

To review OIG’s FAQs regarding the COVID-19 outbreak, please visit

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