decisionhealth Newsletters, Answer Books - 2009 Issue 4 (April)
Drugs / Compliance Tips and Tools / OIG to pharmacies and discount drug card sponsors_Payments for education and outreach create fraud risks
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Article Overview
This article explains an OIG fraud guidance issue involving education and outreach payments connected to discount drug card sponsors and network pharmacies. It is relevant to compliance staff, pharmacy operators, and other healthcare business professionals who need to understand the general fraud-risk areas, oversight considerations, and available compliance resources discussed by the agency.
Why This Topic Matters
The article highlights a compliance area where payment arrangements can raise fraud and anti-kickback concerns for pharmacies and sponsors. It matters because it helps readers recognize the broader risk categories OIG focuses on and where to look for additional agency guidance.
Article Sections
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OIG guidance on education and outreach payments
Introduces the compliance issue and the general concern addressed by OIG for pharmacies and discount drug card sponsors.
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Factors considered in anti-kickback analysis
Summarizes the broad categories of factors investigators may review when evaluating arrangements for potential fraud risk.
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Safe harbor and advisory opinion resources
Notes the general compliance resources referenced for evaluating whether an arrangement may raise sanctions under OIG oversight.
What You Will Learn
- The general compliance concerns OIG raises about education and outreach payments.
- The broad types of factors considered in fraud and anti-kickback reviews.
- The kinds of OIG resources mentioned for evaluating uncertain arrangements.
- The role of pharmacies and discount drug card sponsors in this guidance.
Who Should Read This
- Compliance professionals
- Pharmacy managers and owners
- Healthcare attorneys
- Revenue integrity staff
- Healthcare administrators
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