The Department of Health and Human Services Office of Inspector General (“OIG”) recently issued a new advisory opinion finding that free introductory visits (the “Introductory Visits”) for patients offered by a home health care provider (the “Requestor”) would not violate the Anti-Kickback Statute (“AKS”) or the Civil Monetary Penalties Law (“CMP”). The main issue addressed by the OIG is whether the free Introductory Visits offered by the Requestor constitute prohibited remuneration (broadly defined as anything of value) to patients under the AKS and/or the CMP. (Continue reading).