1. What practical purpose is served by the safe harbors, advisory opinions, and special fraud alerts issued by the Office of the Inspector General (OIG) in the Department of Health and Human Services (DHHS).?
2. When Congress enacted the Anti-Kickback Statute, it wrote five exceptions into the law. After it became law, the OIG issued regulations defining 24 “safe harbors.” What is the difference, if any, between an exception and a safe harbor?