Comment on FR Doc # 2026-12676

Summary: TechInHSR LLC, a regulatory compliance consulting practice, supports the OIG's effort to address fraud and abuse but argues that IRB review and AKS/CMP analysis are distinct functions that should not be conflated. They advocate for a formal safe harbor that codifies existing OIG practices for copay subsidies to reduce administrative burdens while maintaining robust IRB oversight to prevent coercion.