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December 24, 2019 AdvaMed Comments re OIG Value-Based AKS Safe Harbor Proposed Rules


AdvaMed comments regarding OIG–0936–AA10–P: Proposed Rule Regarding Fraud and Abuse Revisions to Safe Harbors Under the Anti-Kickback Statute and Beneficiary Inducements CMP.

Medical Device (“Device”) manufacturers should be included among those entities that are able to utilize all of the final rule’s value-based AKS safe harbors because Device manufacturers can make necessary contributions to advance value-based health care, and concerns about the risk of abuse can be effectively managed through an activity/arrangement-based framework.

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Value-Based Health Care