Honoraria and payment for course faculty

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Reference no: EM133810937

Question

Assume you are a new compliance officer at a pharmaceutical company. You are being asked to review an existing policy that prohibits the company from giving any gifts or items of value to healthcare practitioners of a total annual combined retail value in excess of $100. The policy exempts such items as drug samples, payments to sponsors of education programs, honoraria and payment for course faculty, compensation for research consulting, and educational materials. Would you continue to include these exemptions, or would you recommend that they be removed due to Anti-Kickback Statute concerns? Why?

Reference no: EM133810937

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