On Dec. 23, 2020, the Department of Health and Human Services Office of the Inspector General (OIG) issued Advisory Opinion 20-08 approving an arrangement proposed by a federally qualified health center (FQHC) to offer gift cards to incentivize pediatric patients to attend rescheduled preventative and early intervention care appointments. While gift cards themselves have been a topic of several advisory opinions in the past, this opinion offers insight as to how the OIG may distinguish acceptable inducements to support care from more problematic programs that offer beneficiary inducements merely as an incentive for patients to obtain federally reimbursable items and services.

FQHCs are community-based health care providers that receive funds from the Health Resources and Services Administration (HRSA) health center program to provide primary care services and qualified preventive health services in underserved areas. FQHCs must meet a stringent set of requirements, including providing care on a sliding fee scale based on ability to pay and operating under a governing board that includes patients.

Proposed Arrangement

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