Abstract

The final rule on incentives and contingency management was published last week and goes into effect Jan. 19, 2021. The final rule, issued by the Department of Health and Human Services Office of the Inspector General (HHS OIG), applies to the use of contingency management — the only proven method of treatment for stimulant use disorders — and still considers such payments a kickback, and therefore illegal under fraud and abuse statutes (see “CM, only effective treatment for stimulant disorders, on the ropes as methamphetamine surges, ADAW June 8, https://onlinelibrary.wiley.com/doi/10.1002/adaw.32742 and “HHS doubles down on constraints against contingency management, ADAW August 24, https://onlinelibrary.wiley.com/doi/10.1002/adaw.32812).

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