OIG Finds Safe Harbor Applies to Warranty for Refund of Concierge Fees to Patients Requiring Second Surgery
- May 29, 2026
- Written by AHLA Legal Staff
An orthopedic surgery provider's proposed warranty program to refund certain concierge fees to patients who require revision surgery qualified for safe harbor protection and therefore would not generate prohibited remuneration under the federal Anti-Kickback Statute (AKS), the Department of Health and Human Services Office of Inspector General (OIG) said in an advisory opinion posted May 28.
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