Can I give gas cards or gift cards at an event?

“In marketing, MA organizations may not do any of the following:”

“Offer gifts to beneficiaries, unless the gifts are of nominal value (as governed by guidance published by the HHS OIG), are offered to similarly situated beneficiaries without regard to whether or not the beneficiary enrolls, and are not in the form of cash or other monetary rebates.”

“Nominal gifts may not be in the form of cash, including cash-equivalents, or other monetary rebates.”

“A general gift card that is not restricted to specific retail chains or to specific items and categories would fall under those types that would be considered a cash equivalent (e.g. Visa gift card).”

“Gift cards for retailers or online vendors that sell a wide variety of consumer products would also fall under this prohibition (e.g., Walmart and Amazon).”

“A gift card that can be used for a more limited selection of items or food, would not be considered a cash equivalent (e.g. Starbucks or a Shell Gas gift card).”

“HHS OIG's current interpretation of "nominal value" is set forth in "Office of Inspector General's (OIG's) Policy Statement Regarding Gifts of Nominal Value To Medicare and Medicaid Beneficiaries," and is no more than $15 per item or $75 in the aggregate, per person, per year.”