Adrienne C.’s Post

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Chief Compliance Officer

📝NEW Content from the OIG as of May 31, 2023 - Guidance related to Best Practices with the use of Gift Cards and Exchanging Renumeration with Common Ownership Entities: (5) ✅ How does OIG differentiate between “cash,” “cash equivalents,” and “in-kind” gift cards? How would OIG categorize a gift card to a big-box store? How do you OIG categorize a gift card to a big-box store, the terms of this expressly limit the scope of items the consumer could purchase with such gift card (e.g., the gift card could only be used to purchase fresh food items)? (7) ✅ Does remuneration exchanged between entities with common ownership implicate the Federal anti-kickback statute? *Visit the link below for the full list of questions and answers*

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