The proposed arrangement presented to the OIG involved providing gift cards to q requestor’s existing customers in exchange for their referral to other physician practices. Services provided by the requestor would include data analytics services, EHR consulting and compliance monitoring.
The proposal involves the requestor giving a $25 gift card to its current customers, who recommend their services to prospective physician practice customers, with successful recommendations receiving another $50 gift card, according to the article.
The inspector general determined that the proposed arrangement would not qualify as kickbacks.
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