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Home Care Agencies and Sign-On Bonuses: Understanding the Recent Advisory Opinion of HHS’s Office of Inspector General
On December 30, 2025, the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) published Advisory Opinion No. 25-12 (AO 25-12) concerning home care agencies’ proposal to market compensation packages, including sign-on bonuses, to prospective caregivers with the intention of employing them for the provision of personal assistance services to Medicaid participants “who most often would be family members.”
The OIG determined that the proposed arrangement would result in impermissible remuneration under the federal Anti-Kickback Statute (AKS) and implicate the civil monetary penalty provision prohibiting inducements to beneficiaries (the “Beneficiary Inducements CMP”).
The OIG determined that the proposed arrangement would result in impermissible remuneration under the federal Anti-Kickback Statute (AKS) and implicate the civil monetary penalty provision prohibiting inducements to beneficiaries (the “Beneficiary Inducements CMP”).
