Based on recent enforcement actions and increased scrutiny in telemedicine, the Office of Inspector General (OIG) recently published a Special Fraud Alert 1 regarding fraud concerns in arrangements between healthcare professionals (HCPs) and telemedicine companies (including telehealth and telemarketing companies), providing a list of suspect characteristics that may increase criminal, civil, or administrative liability to parties in such arrangements, depending on the facts and circumstances. The OIG noted that a common element among fraud schemes in the telemedicine space is the use of kickbacks to aggressively recruit and incentivize HCPs to order or prescribe medically unnecessary items and services for purported patients solicited and recruited by telemedicine companies, often delaying needed care or not providing opportunities for HCPs to meaningfully determine the medical necessity of such items or services.