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Beneficiary Inducements in an Evolving Market: Assessing the Risks, Understanding the Benefits, and Drawing the Lines

​In October 2013, AHLA’s Public Interest Committee held a convener session to engage in a discussion of prohibitions on inducements to beneficiaries found in the federal Anti-kickback Statute and Civil Monetary Penalty Law.  Participants represented a wide variety of backgrounds, including in-house counsel; attorneys in private practice who work primarily with hospitals, physicians, pharmaceutical companies, and/or long term care facilities; counsel engaged in patient advocacy, including the AARP; and attorneys now in the private sector who formerly worked in government services on behalf of both regulatory and enforcement agencies.   

The purpose of the convener session was to consider what, if any, changes to these laws or additional guidance from the government might be beneficial in light of both the current structure of the health care delivery system and the implications of health care reform. Representatives from the Centers for Medicare & Medicaid Services, the Centers for Medicare & Medicaid Innovation, and the Office of the Inspector General observed, but did not participate in, the discussion.  The Public Interest Committee published a White Paper​, which sets forth a summary of the discussion, presenting policy issues as well as practical considerations.​

We sincerely thank our participants: 
  • Robert G. Homchick, Davis Wright Tremaine LLP 
  • Gary W. Eiland, King & Spalding LLP 
  • David W. Grauer, Squire Sanders 
  • John V. Jacobi, Seton Hall University School of Law 
  • Julie E. Kass, OBER|KALER 
  • Keith D. Lind, Senior Policy Advisor 
  • Rachel Ludwig, Health Care Fellow 
  • Kevin G. McAnaney, Law Offices of Kevin McAnaney 
  • Rachel A. Seifert, Community Health Systems 
  • Harvey M. Tettlebaum, Husch Blackwell LLP 
  • Daryl Todd, Johnson & Johnson 
  • Bruce J. Toppin, North Mississippi Health Services 
  • Cynthia F. Wisner, Trinity Health
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