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New Kickback Safe Harbor for Federally Qualified Health Centers

Client Alert | less than 1 min read | 07.01.05

The HHS Office of Inspector General has issued a proposed new anti-kickback law safe harbor protecting transfers of goods, items, services, donations and loans to federally qualified health centers if specific conditions are met. The proposed regulation implements a provision of the Medicare Modernization Act calling for the new safe harbor where an arrangement contributes meaningfully to the health center's provision of services to a medically underserved population.  The comment period on the proposed regulation runs until August 1, 2005. Click here to view the proposed rules published in the Federal Register.

Insights

Client Alert | 2 min read | 12.29.25

FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company

GAO’s key personnel rule is well-known—and often a source of frustration— amongst government contractors.  Proposed key personnel who become “unavailable” prior to contract award—especially where they have accepted employment with a different company—may doom an offeror’s proposal by rendering it noncompliant with solicitation requirements.  But GAO’s recent decision in FYI – For Your Information, Inc., B-423774, B-423774.2 (Dec. 19, 2025) provides some potential relief from that rule. ...