FAQs–Application of OIG’s Administrative Enforcement Authorities to Arrangements Directly Connected to the Coronavirus Disease 2019 (COVID-19) Public Health Emergency
The HHS Office of the Inspector General (OIG) issued updated FAQs regarding application of OIG’s administrative enforcement authorities to arrangements directly connected to COVID-19. The new FAQ addresses whether clinical laboratories may offer free COVID-19 antibody testing to federal healthcare program beneficiaries who are contemporaneously receiving other medically necessary blood tests during the COVID-19 public health emergency. The guidance clarifies that the arrangement described in the FAQs offers the possibility of substantial public health benefits through the identification of additional potential convalescent plasma donors and valuable public health information and data. Provided the arrangement includes a series of safeguards enumerated in the FAQs, OIG asserts that the scenario would post a sufficiently low risk of fraud and abuse.