The December alert focuses on two areas: payments from MA organizations to healthcare professionals linked to MA plan marketing and enrollment, and payments from HCPs to agents or brokers involved in MA plan enrollments.
These arrangements may violate federal anti-kickback statutes by incentivizing the steering of Medicare enrollees toward plans or providers based on payments rather than suitability. OIG is concerned about unfair competition and potential harm to beneficiaries, and MA plans should evaluate their existing partnerships and payment structures for compliance to reduce legal and reputational risks.
