Federal Anti-Kickback StatuteSection 1128B(b) of the Social Security Act (Act), (42 U.S.C. Congress later expanded the CMP law and the scope of exclusion to apply to all Federal health care programs, but the CMP applicable to beneficiary inducements remains limited to Medicare and State health care program beneficiaries. The Special Advisory Bulletin includes several guardrails intended to mitigate risk under the Federal anti-kickback statute. Please identify any operational difficulties in implementing those guardrails and potential solutions to ensure appropriate guardrails are in place to protect Federal health care program enrollees. In addition, please explain whether additional guardrails may be necessary to sufficiently address fraud and abuse risks under the Federal anti-kickback statute.