Keystone Physician Magazine - Summer 2019

Page 47

3. Only attend legitimate educational presentations that have a valid business justification. 4. Never accept speaker fees from any drug or device manufacturer that are either above fair market value or where the physician was selected based upon prescribing history. 5. Physicians should not attend three or more events related to the same drug within six months; serve as a speaker for a given drug then attend a lecture about the same drug within 12 months; or attend any speaker program where the food and beverage cost exceeds $65 per person.

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The defendants in this case are limited to pharmaceutical manufacturers and their affiliated corporate entities. The OIG and Department of Justice, however, are continuing to target the recipients of improper remuneration and inducements, illustrated most recently in U.S. v. Johnson/Halsell, in which physicians who allegedly accepted illegal kickback payments from a pharmaceutical company were required to pay $128,000.

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6. Compliance policies and programs are only effective if they are thoroughly implemented.

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