The HHS Office of Inspector General (OIG) issued Advisory Opinion No. 24-08 (opinion) on Sept. 10, 2024, regarding a "requestor's" proposal to share a percentage of its savings with certain groups to which it provides coverage. Specifically, the requestor inquired as to whether the "proposed arrangement," as discussed below, would warrant sanctions under Sections 1128(b)(7) or 1128A(a)(7) of the Social Security Act (SSA) as they relate to the federal Anti-Kickback Statute (AKS). The opinion concludes that, if undertaken, the proposed arrangement would generate prohibited remuneration under the AKS (if the requisite intent were present).