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
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On October 3, 2025, the Sixth Circuit reaffirmed that the attorney-client privilege and the work-product doctrine protections apply to materials created during attorney-led internal investigations. In re FirstEnergy Corp., No. 24-3654 (6th Cir. Oct. 3, 2025).
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