OIG Clears Limited Free Orthodontic Services in Advisory Opinion 26-09

On May 1, 2026, OIG issued Advisory Opinion 26-09 addressing a pediatric dental and orthodontic provider's proposal to offer free orthodontic treatment to one patient annually at each of its three practice locations. The opinion provides guidance on how such charitable arrangements may comply with federal anti-kickback statute and beneficiary inducement provisions. For Medicaid managed care dental plans and MCOs with dental benefits, this opinion clarifies acceptable parameters for provider charitable care arrangements that could affect network adequacy and access strategies, particularly for orthodontic services where cost barriers are common.

Dental · Managed Care