Pharmaceutical and Medical Device Company Payments to Healthcare Professionals (Part II of III)
Given the significant risks posed by transfers of money and other items of value to physicians, pharmaceutical and medical device companies have to implement appropriate controls governing such payments. The federal Anti-Kickback Statute (“AKS”) prohibits the offering, paying, soliciting or receiving anything of value to induce or reward referrals or generate federal health care program business. The statute defines “anything of value” broadly; criminal penalties...