In OIG Advisory Opinion 26-16, regulators declined to sanction an FQHC’s Food as Medicine program, offering crucial guidance for digital health companies, health systems, and payors. While free produce triggers Anti-Kickback Statute (AKS) and Beneficiary Inducements CMP risks, OIG exercised enforcement discretion due to strict clinical oversight, financial-need screening, and operational safeguards. Nixon Law Group breaks down the 5 key compliance principles needed to safely structure Food as Medicine and SDOH initiatives.