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    December 30, 2019  

    Acting Inspector General Joanne Chiedi
    Office of Inspector General,
    Department of Health and Human Services
    330 Independence Avenue, S.W., Room 5513
    Washington, D.C. 20201

    Re: OIG-0936-AA10-P Medicare and State Healthcare Programs: Fraud and Abuse; Revisions To Safe Harbors Under the Anti-Kickback Statute, and Civil Monetary Penalty Rules Regarding Beneficiary Inducements

    Dear Acting Inspector General Chiedi,

    The Medical Group Management Association (MGMA) is pleased to submit the following comments to the Office of Inspector General’s (OIG) proposed rule modernizing the Anti-kickback Statute (AKS). We commend OIG for recognizing the need to modernize existing laws to reflect a more coordinated approach to care delivery and appreciate the opportunity to comment on OIG’s proposed regulations.

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