tci Medicare Compliance & Reimbursement - 2003 Issue 18

Business Arrangements: 5 RED FLAGS FOR DRUGMAKER-DOC BUSINESS ARRANGEMENTS

Physicians and pharmaceutical companies are in the kickback enforcement crosshairs, as the HHS Office of Inspector General's recent compliance guidance for drugmakers makes clear. Any time a physician gets something of value from a pharma company - whether it's a consulting fee or a free dinner - kickback concerns may come into play. While the OIG says docs and drugmakers should fit their business arrangements into a safe harbor (such as those for personal services and management contracts) that's not always possible. But the agency does offer some advice on this tricky topic. When the safe harbor option is...

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