Lexology April 22, 2025
Krieg DeVault

A recent advisory opinion from the Office of Inspector General (“OIG”) provides welcome clarity and encouragement to community health centers looking for ways to incentivize patient access to care. Advisory Opinion 25-02 continues the OIG’s favorable support of strategies designed to connect underserved individuals with needed care, while also reminding health centers to be mindful of federal fraud and abuse laws when implementing these strategies.

In Advisory Opinion 25-02, the OIG evaluated a Federally Qualified Health Center’s (“FQHC”) proposal to offer free non-medical services, such as childcare, legal aid, and access to food or baby supplies (“Additional Services”) to its patients, including individuals who hadn’t seen a primary care provider in the past year. FQHC staff would then offer such...

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