For many years, providers have struggled with whether it is a violation of the anti-kickback statute to provide free or discounted transportation to patients. The OIG has now offered a new safe harbor for local transport, among some others that are not so relevant to our clients. In addition under the civil money penalties provisions, they have created exceptions for beneficiary inducements that promote access to care, or another where the patient has financial need.  The devil, of course, is in the details. Our AGG Note addresses the extended commentary which was published with the relatively brief regulations setting forth both the new safe harbors and the new CMP exceptions that are most relevant to physicians.