"We are writing in response to your request for an advisory opinion regarding the use of a 'preferred hospital' network as part of Medicare Supplemental Health Insurance (Medigap) policies, whereby [name redacted] would indirectly contract with hospitals for discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay (the Proposed Arrangement) ... [A]lthough the Proposed Arrangement could potentially generate prohibited remuneration under the anti-kickback statute ... the [OIG] would not impose administrative sanctions on [name redacted] under sections 1128(b)(7) or 1128A(a)(7) of the Act ... in connection with the Proposed Arrangement. In addition, the OIG would not impose administrative sanctions on [name redacted] under section 1128A(a)(5) of the Act in connection with the Proposed Arrangement."