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OIG Safe Harbor Authority CMS expects to make a determination, if this rulemaking is finalized, that the anti-kickback statute safe harbor for CMS-sponsored model patient incentives ( 1001.952(ii)(2)) is available to protect patient incentives that may be permitted under the final rule, if issued

Unanswered or double-marked responses create ambiguity and can lead to incorrect clearance decisions

their meaning was the fulcrum on which the law turned and determined whether society was regulated well or poorly

There are variables

At one point he quipped, We're turning into hunger artists! Our feet, though not frostbitten, were numb and wrinkled with trench foot from 15 days jammed into frozen boots