Structuring Patient Incentive Programs to Minimize Risk Under Federal Laws, an Issue Brief written by Feldesman Partner Adam J. Falcone, was recently published by the National Association of Community Health Centers (NACHC). In the article, Mr. Falcone outlines federal laws implicated by patient incentive programs and potential methods for health centers to structure their programs to be compliant. 

Throughout the publication, Mr. Falcone defines the Beneficiary Inducement Prohibition and Anti-Kickback Statute and details important regulatory exceptions and safe harbors for health center incentive programs. Additionally, he outlines top compliance concerns and recent advisory options from the U.S. Department of Health and Human Services’ Office of the Inspector General.

We are happy for Mr. Falcone’s opportunity to discuss such a critical topic for health centers in this Issue Brief from NACHC. The full article can be accessed here.

On February 11 – 12, 2025, Mr. Falcone will lead a two-part webinar series on patient incentive programs. More information on these webinars can be viewed here.