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. / tuesday, november , / notices see cfr . this bulletin focuses on the application of the federal anti-kickback statute. other potential risk areas, including, for example, potential liability under the false claims act, u.s.c. – , or other federal or state laws, are not addressed here. moreover, this
amounts pose risks under the anti-kickback statute that are not addressed here. similarly, paps established by health plans that subsidize cost sharing or premium amounts under part d raise different issues and may require a different analysis. while this bulletin may provide some useful guidance for other...
https://www.oig.hhs.gov/fraud/docs/alertsandbulletins/2005/2005PAPSpecialAdvisoryBulletin.pdf