OIG OKs gifts and prizes to encourage COVID-19 vaccinations

by: Julia Kyles, CPC May 24, 2021

Freebies to encourage Medicare and other federal health care patients to get vaccinated are fine -- but mind the requirements.

Crawdads, tickets to amusement parks, money: These are a small sample of the incentives that are being used to encourage people to get vaccinated against COVID-19. But is it safe for health care providers and other health organizations to offer freebies to Medicare patients or other federal health care beneficiaries?

Yes, it is, the HHS Office of Inspector General (OIG) said in an FAQ posted on its COVID-19 portal today. The offer of beer, doughnuts, passes to a local museum and other goodies does not violate the Anti-Kickback Statute or the beneficiary inducements Civil Money Penalty (CMP) if offered to induce people to get COVID vaccinations.

“In the limited context of the COVID-19 public health emergency, a health care provider, supplier, or managed care organization offering or providing a reward or incentive in connection with the beneficiary receiving the COVID-19 vaccine (either one or both doses) would be sufficiently low risk under” the Anti-kickback Statute and beneficiary inducements civil monetary penalty.

Of course there are some caveats, starting with the vaccine itself: It must be approved by the Food and Drug Administration for COVID-19 and administered in accordance with all other federal and state rules, the OIG says.

As for the incentive or reward itself, health care organizations should make sure that it meets the following five requirements:

It is furnished in connection with a required dose of a COVID-19 vaccine. This could include one or two doses, depending on the vaccine, the OIG notes.
It is not tied to any other arrangement or agreement between the organization that is offering the incentive and the patient.
It is not based on the patient’s use of other items or services that are covered by Medicare or other federal health care programs.
It doesn’t take the patient’s insurance coverage into account “unless the incentive or reward is being offered by a managed care organization and eligibility is limited to its enrollees.”
It is provided during the COVID-19 public health emergency, which will is set to expire July 20 if the HHS Secretary does not extend it another 90 days.

Blog Tags: anti-fraud, COVID-19, OIG

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