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

December 6, 2022

Access the on-demand webinar here.

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.

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: 
Event starts: 
12/06/2022 - 1:00pm EST
Event ends: 
12/06/2022 - 2:00pm EST


Adam J. Falcone is a Partner in FTLF’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]

Participants can earn up to 1.20 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.


If you purchase CPE credit for this webinar you must satisfy the following conditions in order to receive your certificate:

  1. Answer at least 3 of the 5 polling questions during the webinar
  2. Complete the evaluation survey after the conclusion of the webinar or in the follow-up email

Upon completion of these requirements, FTLF will email you your CPE Certificate within seven (7) business days.


  • Prerequisites: None 
  • Target Audience: C-Suite, Compliance Officers and Professionals, Population Health and Quality Improvement Staff 
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based
  • Attendance Requirements: In order to be awarded the full credits, you must respond to three (3) out of five (5) polling questions.

Feldesman Tucker Leifer Fidell LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website (formerly

Available Credit

  • 1.00 Certificate of Attendance


Please login or register to take this course.

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.

Access to the recorded version of this webinar is included in your purchase.


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