OIG Reiterates a Core Message: Stark Compliance and Fair Market Value Alone Do Not Shield Against Anti-Kickback Statute Risk

On April 23, 2026, the HHS Office of Inspector General (OIG) quietly—but pointedly—added two new FAQs to its “General Questions Regarding Certain Fraud and Abuse Authorities.” Although the principles articulated are not new, the timing and clarity of these FAQs reflect OIG’s continued effort to correct common—and risky—misunderstandings in the health care industry regarding the federal Anti‑Kickback Statute (AKS), the physician self‑referral law (“Stark”), and the role of fair market value (FMV)... By: Robinson+Cole Health Law Diagnosis