In early March 2022, the Office of the Inspector General (OIG) within the U.S. Department of Health and Human Services (HHS) issued an advisory opinion on the contingency management (CM) approach for substance use disorder treatment. Specifically, the OIG concluded that DynamiCare Health Inc.’s app-based CM program does not carry the risk of running afoul of federal anti-kickback laws and inducement prohibitions. Crucially, the HHS-OIG reported that treatment providers can go above the previously enforced $75 cap for CM.

The advisory opinion was issued in response to a submission by DynamiCare and is limited to DynamiCare’s app-based CM protocol. According to The National Council, the decision clears CM for more routine use in publicly funded SUD treatment programs and at Medicaid-funded health care facilities.