OIG examined a case in which patients received a $25 retail gift card for completing two online modules from a physician’s office. The first module was on non-surgical treatment options, and the second module on surgery preparation.
Patients received the gift card regardless of their decision to undergo surgery, and the program was open for anyone to complete, not just those who were imminently looking for an operation.
OIG concluded this program had a very low risk for fraud and abuse and did not violate anti-kickback statute because the low amount of compensation offered was unlikely to drastically alter whether patients decided to undergo surgery.
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