Fraud and Abuse Discussion

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Sacred Heart Medical Center delivers thousands of babies each years to indigent mothers.It recently proposed a novel "MoM" Program," which offers balanced meals once a day for six weeks to indigent mothers who are breastfeeding their infants. Sacred Heart's goal is to encourage moms to breastfeed while also ensuring that breastfeeding moms are able to eat more healthily at least for the first six weeks.Meals on Wheels has agreed to help with the initiative.Everyone is excited about the program except the Hospital's Compliance Officer who is concerned that the program, while laudable, may be interpreted as an improper gift or inducement, and therefore, inconsistent with federal law.What are your thoughts?Can this proposed program be modified to comply with existing laws? If so, how? If not, why not?