"The Proposed Arrangement is a straightforward agreement by the Network Hospitals to discount the Medicare inpatient deductible for the Requestors' Policyholders -- an amount for which the Requestors otherwise would be liable.... In addition, the Requestors would pass back a portion of their savings, in the form of premium credits, to any Policyholder who has an inpatient stay at a Network Hospital.... [A]lthough the Proposed Arrangement could potentially generate prohibited remuneration under the anti-kickback statute if the requisite intent to induce or reward referrals of Federal health care program business were present, the OIG would not impose administrative sanctions ... under sections 1128(b)(7) or 1128A(a)(7) of the [Social Security Act] ... in connection with the Proposed Arrangement. In addition, the OIG would not impose administrative sanctions ... under section 1128A(a)(5) ... in connection with the Proposed Arrangement."