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The Department of Health and Human Services' Office of Inspector General (OIC) issued this letter on January 24, 2019. The letter is in response to a request for an advisory opinion regarding a pharmaceutical manufacturer's proposal to loan, on a temporary basis, a limited-functionality smartphone to financially needy consumers who do not have the technology necessary to receive adherence data from a sensor embedded in prescribed antipsychotic medication (the "Proposed Arrangement"). OIC concluded that the Proposed Arrangement would not constitute grounds for the imposition of civil monetary penalties under section 1128A(a)(5) of the Social Security Act . . .

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