Physician Payments Disclosure and Aggregate Spend:
|
|
- Quentin Patrick
- 5 years ago
- Views:
Transcription
1 Physician Payments Disclosure and Aggregate Spend: Navigating Conflicting and Unclear State Laws and Regulations A Guide for Device Manufacturers October 26, 2010 Colin J. Zick Foley Hoag LLP czick@foleyhoag.com (617) Foley Hoag LLP. All Rights Reserved. 1
2 How You Spend Your Marketing Dollars Is A National Law Enforcement Issue Suits Allege Medical-Device Makers Paid Physicians to Use Their Products in Off-Label Applications: Earlier this year, in an article called Surgical-Device Firms Walk Fine Line, the Wall Street Journal reported that former employees of certain medical-devicemakers allege in lawsuits unsealed in a Texas federal court that the companies paid kickbacks to heart surgeons to get the doctors to use their products in an off-label application: to treat atrial fibrillation. The suits name at least four companies whose products are among those used in surgery to treat the heart condition, including AtriCure, Medtronic, St. Jude Medical, and Boston Scientific. The companies are accused of taking part in a "'fraudulent marketing and inducement campaign,' involving kickbacks to doctors and hospitals," which "resulted in excessive charges to the Medicare insurance program." The cases against Boston Scientific, Medtronic, and AtriCure also allege that these companies marketed surgical ablation equipment as a treatment for atrial fibrillation even though it was not approved by the Food and Drug Administration to treat that condition Foley Hoag LLP. All Rights Reserved. Presentation Title 2
3 Anti-Kickback Statute Applies only in situations where payment is provided by government health care program. The federal anti-kickback statute prohibits remuneration to induce referrals. Generally, the difficulty in determining potential liability lies in distinguishing between remuneration intended to induce referrals and remuneration paid to the referral source in return for legitimate services and in appropriate amounts Foley Hoag LLP. All Rights Reserved. Presentation Title 3
4 Device Manufacturer and Hospitals Pay Nearly $4 Million to Resolve Fraud Claim St. Jude Medical Inc., a heart device manufacturer and two hospitals paid the United States $3,898,300 to resolve false claim allegations. The Justice Department alleged that St. Jude paid illegal kickbacks to two hospitals to secure heart-device business. The kickbacks included alleged rebates that were "retroactive" and paid based on a hospital s previous purchases of St. Jude heart-device equipment and rebates that St. Jude paid for purchases of heart-device equipment sold by its competitors to induce purchases of similar equipment from St. Jude in the future Foley Hoag LLP. All Rights Reserved. Presentation Title 4
5 RELEVANT MARKETING CODES FOR DEVICES OIG Compliance Guidance: Compliance Program Guidance for Pharmaceutical Manufacturers, issued by the Department of Health and Human Services Office of Inspector General, 68 Fed. Reg (May 5, 2003) Primary Trade Association Code: AdvaMed Code of Ethics on Interactions with Healthcare Professionals Foley Hoag LLP. All Rights Reserved. Presentation Title 5
6 OIG S REQUIREMENTS Implementing written policies and procedures; Designating a compliance officer and compliance committee; Conducting effective training and education; Developing effective lines of communication; Conducting internal monitoring and auditing; Enforcing standards through well-publicized disciplinary guidelines; and Responding promptly to detected problems and undertaking corrective action Foley Hoag LLP. All Rights Reserved. Presentation Title 6
7 A Number of States Have Enacted Gift Limits and Reporting States with such provisions for device manufacturers include: Massachusetts California Vermont Key elements of these statutes: Gift limits and prohibitions Individual and aggregate reporting obligations Other states require compliance plans: California Nevada Connecticut Foley Hoag LLP. All Rights Reserved. Presentation Title 7
8 Summary of Current State Laws for Device Manufacturers Foley Hoag LLP. All Rights Reserved. Presentation Title 8
9 The Newest Law: Connecticut Public Act No On or before January 1, 2011, each pharmaceutical or medical device manufacturing company shall adopt and implement a code that is consistent with, and minimally contains all of the requirements prescribed in, the [PhRMA] "Code on Interaction with Healthcare Professionals" or AdvaMed's "Code of Ethics on Interactions with Health Care Professionals" as such codes were in effect on January 1, Each pharmaceutical or medical device manufacturing company shall adopt a comprehensive compliance program in accordance with the guidelines provided in the "Compliance Program Guidance for Pharmaceutical Manufacturers" dated April, 2003 and issued [HHS OIG] Foley Hoag LLP. All Rights Reserved. Presentation Title 9
10 Massachusetts: Perhaps the Most Challenging U.S. Regulatory Environment The Massachusetts rules went into effect July 1, 2009 Massachusetts is probably the most challenging regulatory environment in the U.S. because: The AG has had a difficult year, and drug and device companies may seem like an easy target. Massachusetts has a significant number of doctors who are in key product markets Massachusetts rules are so strict: one of the broadest definitions of sales and marketing of any state Massachusetts prohibits certain payments to providers by pharmaceutical and medical device manufacturers Massachusetts is one of the few states to make disclosure of data part of the public record Foley Hoag LLP. All Rights Reserved. Presentation Title 10
11 Who are the Covered Health Care Practitioners under Massachusetts law? Health Care Practitioners (HCPs) covered by the regulations include those who: Prescribe prescription drugs for any person; and Are licensed to provide health care in Massachusetts (also partnerships or corporations comprised of such persons or their agents). Does not include full-time company employees or board members who are not HCPs. Does not include hospitals Foley Hoag LLP. All Rights Reserved. Presentation Title 11
12 MA Code of Conduct Meals and Gifts Prohibits payments to HCPs for meals that are: Part of an entertainment event Offered without an informational presentation made by a marketing agent, or without the agent being present Outside of the HCP s office or hospital setting Hospital, academic medical center, or specialized training facility Provided to the HCP s spouse or other guest Prohibits gifts to HCPs including: Providing or paying for entertainment or recreation items of any value to any nonemployee HCP Payments in cash or cash equivalents except as compensation for services Expressly prohibits complimentary items such as pens, coffee mugs, gift cards, etc. Grants, scholarships, contracts or practice items in exchange for prescribing drugs or using medical devices Foley Hoag LLP. All Rights Reserved. Presentation Title 12
13 MA Code of Conduct Prohibited Continuing Ed Payments Sponsorship of continuing ed seminars not accredited or meeting those standards Cost of travel, lodging or other personal expenses of non-faculty at conferences and meetings Funding for time spent by HCPs for participation in conferences Exception for reasonable compensation or reimbursement to a HCP serving as a speaker or providing actual substantive services Direct payment for meals at conferences Allows general financial support to conference provider or organizer Foley Hoag LLP. All Rights Reserved. Presentation Title 13
14 MA Code of Conduct What It Allows Provision of peer reviewed academic, scientific or clinical information Advertising in peer reviewed academic, scientific or clinical journals Limited free use of devices for use by and education of patients Compensation for professional consulting services in connection with research and clinical trials Expenses for technical training of a medical device, including travel and lodging, if part of a purchase contract Price concessions, including rebates and discounts Foley Hoag LLP. All Rights Reserved. Presentation Title 14
15 MA Disclosure Requirements Requires covered companies employing marketers to disclose annually the: Value, Nature, Purpose, and Recipient of any fee, payment, subsidy, or other economic benefit with a value of at least $50 which a manufacturer provides, directly or through its agents to any covered recipient Broader than just HCPs: person authorized to prescribe, dispense or purchase prescription drugs or medical devices in the Commonwealth, including a hospital, nursing home, pharmacist, health benefit plan administrator, or a health care practitioner Employees are excluded in connection with sales and marketing activities Foley Hoag LLP. All Rights Reserved. Presentation Title 15
16 Questions Left Unanswered By the MA Regulations Meals are prohibited, but what about drinks at a bar? Can the president of my company have lunch with a primary investigator to talk about the study the PI is conducting on our product? How do we determine who is a HCP? Do we have to research every doctor we come into contact with? Foley Hoag LLP. All Rights Reserved. Presentation Title 16
Fraud and Abuse in the Sale and Marketing of Drugs ACI 10 th National Forum
PHYSICIAN PAYMENTS: Building a Dynamic Aggregate Spend Program That Complies with and Accounts for the Disparities Between Current and Pending State Legislation Fraud and Abuse in the Sale and Marketing
More informationComparison of the AdvaMed Code of Ethics and the Eucomed Code of Business Practice
Comparison of the AdvaMed Code of Ethics and the Eucomed Code of Business Practice Note: The Eucomed Code also contains Guidelines on Competition Law. These principles discuss trade association rules and
More informationCAUTION. Introduction
Introduction Most physicians strive to work ethically, render high-quality medical care to their patients, and submit proper claims for payment. Society places enormous trust in physicians, and rightly
More informationPhysician/Industry Contacts: Updated Focus on CME & Grassley Looks at Possible Research Conflicts
Physician/Industry Contacts: Updated Focus on CME & Grassley Looks at Possible Research Conflicts AdvaMed Webinar // October 28, 2008 R. Michael Scarano, Jr. Heidi A. Sorensen Judith A. Waltz 10/20/2008
More information> TITLE 13. LAW AND PUBLIC SAFETY
N.J.A.C. 13:45J-1.1 13:45J-1.1 Purpose The rules in this chapter regulate the receipt and acceptance by prescribers of anything of value from pharmaceutical manufacturers to ensure that such relationships
More informationCBI s 7 th Annual Medical Device and Diagnostics Compliance Congress
CBI s 7 th Annual Medical Device and Diagnostics Compliance Congress Compliance Risk Areas related to Educational Programs and Product Training June 7-8, 2011 Laura Keidan Martin National Chair, Health
More informationARNOLD & PORTER UPDATE
ARNOLD & PORTER UPDATE Guide for Pharmaceutical Industry October 2002 On Monday, September 30, 2002, the Office of Inspector General, U.S. Department of Health and Human Services ( HHS OIG or OIG ) released
More informationFOR REFERENCE ONLY. Document Change Record: COR NUMBER INITIATOR DESCRIPTION OF CHANGE DATE OF CHANGE REV #
Title: Relationships with Health Care Professionals Document Change Record: REV # DATE OF CHANGE COR NUMBER INITIATOR OF CHANGE DESCRIPTION OF CHANGE 0 9/18/09 16795 Cheryl Garvin Initial Release Quality
More informationNew Jersey issues rules to chill drug manufacturer payments to prescribers
New Jersey issues rules to chill drug manufacturer payments to prescribers January 10, 2018 The New Jersey Attorney General plans to finalize new limits on payments and other benefits that New Jersey licensed
More informationDaiichi Sankyo Group Global Marketing Code of Conduct
Daiichi Sankyo Group Global Marketing Code of Conduct TABLE OF CONTENTS 1. PURPOSE... 3 2. SCOPE... 3 3. TERMS... 3 4. COMPLIANCE WITH LOCAL LAWS, REGULATIONS AND INDUSTRY CODES... 4 5. BASIS OF INTERACTIONS...
More informationDraft ASHP Guidelines on Pharmacists Relationships with Industry
Draft ASHP Guidelines on Pharmacists Relationships with Industry 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Pharmacists can choose to pursue an ethic that
More informationASSOCIATION FOR ACCESSIBLE MEDICINES Code of Business Ethics. March 2018
ASSOCIATION FOR ACCESSIBLE MEDICINES Code of Business Ethics March 2018 Introduction Improving patient access to affordable medicines is a core value of companies that develop and manufacture generic and
More informationThe Mexico City Principles For Voluntary Codes of Business Ethics in the Biopharmaceutical Sector
The Mexico City Principles For Voluntary Codes of Business Ethics in the Biopharmaceutical Sector E thical interactions help ensure that medical decisions are made in the best interests of patients. For
More informationCompliance Program, Code of Conduct, and HIPAA
Compliance Program, Code of Conduct, and HIPAA Agenda Introduction to Compliance The Compliance Program Code of Conduct Reporting Concerns HIPAA Why have a Compliance Program Procedures to follow applicable
More informationMedicare Advantage and Part D Fraud, Waste and Abuse Compliance Training 2015
Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training 2015 Overview This Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training for first-tier, downstream and related
More informationStark, False Claims and Anti- Kickback Laws: Easy Ways to Stay Compliant with the Big Three in Healthcare
Stark, False Claims and Anti- Kickback Laws: Easy Ways to Stay Compliant with the Big Three in Healthcare In health care, we are blessed with an abundance of rules, policies, standards and laws. In Health
More informationVENDOR RELATIONS POLICY TRAINING
VENDOR RELATIONS POLICY TRAINING INTRODUCTION Vendor Relations Policy Key Points All employees of the University of California are subject to the conflict-of-interest provisions of the Political Reform
More informationAshland Hospital Corporation d/b/a King s Daughters Medical Center Corporate Compliance Handbook
( Medical Center ) conducts itself in accord with the highest levels of business ethics and in compliance with applicable laws. This goal can be achieved and maintained only through the integrity and high
More informationCode on Interactions with Healthcare. Professionals
Code on Interactions with Healthcare Professionals Table of Contents Preamble 1 Basis of Interactions 2 Informational Presentations by Pharmaceutical Company Representatives and Accompanying Meals 3 Prohibition
More informationAPACMED CODE OF ETHICAL CONDUCT FOR INTERACTIONS WITH HEALTH CARE PROFESSIONALS
APACMED CODE OF ETHICAL CONDUCT FOR INTERACTIONS WITH HEALTH CARE PROFESSIONALS APACMED MISSION: Our mission is to improve the standards of care through innovative collaborations among stakeholders to
More informationOn April 16, 2008, the Department. Draft Supplemental. Compliance Program Guidance for Nursing. Facilities
Draft Supplemental Compliance Program Guidance for Nursing Facilities By Cheryl L. Wagonhurst, Esq, CCEP; and Nathaniel M. Lacktman, Esq, CCEP Editor s note: Cheryl L. Wagonhurst is a partner with the
More informationLivaNova Terms and Conditions for Donations and Grants
LivaNova Terms and Conditions for Donations and Grants The following Terms and Conditions apply to all LivaNova Donations and Grants approved by the LivaNova regional Donation and Grant Committees, including;
More informationCOMPARISON CHART: ADVAMED CODE (2005), REVISED ADVAMED CODE (EFF. 7/1/2009) AND REVISED PHRMA CODE (EFF. 1/1/2009)
COMPARISON CHART: ADVAMED CODE (2005), REVISED ADVAMED CODE (EFF. 7/1/2009) AND REVISED PHRMA CODE (EFF. 1/1/2009) Subject 1 AdvaMed Code (2005) Revised AdvaMed Code (eff. 7/1/2009) 2 Revised PhRMA Code
More informationCompliance Plan. Table of Contents. Introduction... 3
Compliance Plan Compliance Plan Table of Contents Introduction... 3 Administrative Structure... 4 A. CorporateCompliance Officer... 4 B. Compliance Committee... 5 C. Hospital Compliance Officer Communications...
More informationMedicare Advantage and Part D Compliance Training. 42 CFR Parts and
Medicare Advantage and Part D Compliance Training 42 CFR Parts 422.503 and 423.504 Background > As a Medicare Advantage (MA) and Part D (PDP) Plan Sponsor ( Sponsor ), Blue Cross and Blue Shield Northern
More informationFlorida International University Herbert Wertheim College of Medicine Industry Relations Policy and Guidelines 2/16/15
Table of Contents Florida International University Herbert Wertheim College of Medicine Industry Relations Policy and Guidelines 2/16/15 1. INTRODUCTION AND SCOPE OF POLICY 1 2. DEFINITIONS 1 3. STATEMENT
More informationAVOIDING HEALTHCARE FRAUD AND ABUSE; Responsibility, Protection, Prevention
AVOIDING HEALTHCARE FRAUD AND ABUSE; Responsibility, Protection, Prevention Presented by: www.thehealthlawfirm.com Copyright 2017. George F. Indest III. All rights reserved. George F. Indest III, J.D.,
More informationA Day in the Life of a Compliance Officer
A Day in the Life of a Compliance Officer (for small physician practices) Mina Sellami, MBA, PMP, JD MedProv, LLC Julia Konovalov Medical Business Partners September 29, 2016 Agenda Government Regulations
More information136 Risk Management and Legal Issues for the Practice. Jane Wood
136 Risk Management and Legal Issues for the Practice Jane Wood 2011 Annual Meeting Las Vegas, NV AMERICAN SOCIETY FOR CLINICAL PATHOLOGY 33 W. Monroe, Ste. 1600 Chicago, IL 60603 136 Risk Management and
More informationOIG Opines On Propriety Of ED On-Call Coverage Arrangements By Michael Paddock and Lauren Kim, Crowell & Moring LLP*
OIG Opines On Propriety Of ED On-Call Coverage Arrangements By Michael Paddock and Lauren Kim, Crowell & Moring LLP* Over the last several years, due in part to the growing financial burden on both physicians
More informationDEPARTMENT OF HEALTH & HUMAN SERVICES OFFICE OF INSPECTOR GENERAL
DEPARTMENT OF HEALTH & HUMAN SERVICES OFFICE OF INSPECTOR GENERAL Washington, D.C. 20201 The Office of Inspector General (OIG) for the U.S. Department of Health & Human Services has created the educational
More informationFraud, Abuse, & Waste, Oh My! Developing an Effective Compliance Program
Fraud, Abuse, & Waste, Oh My! Developing an Effective Compliance Program Program speaker The speaker for this program is Arlene Luu, RN, BSN, JD, CPHRM, Senior Patient Safety & Risk Consultant, MedPro
More informationYALE-NEW HAVEN HOSPITAL MEDICAL STAFF POLICY & PROCEDURE CONFLICT OF INTEREST
YALE-NEW HAVEN HOSPITAL MEDICAL STAFF POLICY & PROCEDURE CONFLICT OF INTEREST Definitions External financial interests can create conflicts when they provide an incentive to a Medical Staff member to affect
More informationProtecting Health Information: Health Data Security Training
Protecting Health Information: Health Data Security Training How to secure patient information and manage your obligations under HIPAA, the HITECH Act and other federal and state data privacy and security
More informationCompliance Program And Code of Conduct. United Regional Health Care System
Compliance Program And Code of Conduct United Regional Health Care System TABLE OF CONTENTS Page MESSAGE FROM OUR PRESIDENT... 1 COMPLIANCE PROGRAM... 2 Program Structure...2 Management s Responsibilities
More informationUMass Memorial Medical Center Policy 1143 Vendor Relationships
Page 1 of 10 (Vendor Relationships) UMass Memorial Medical Center Policy 1143 Vendor Relationships Developed By: Compliance Office Effective Date: 12/3/2012 Approved by: Jennifer Daley, MD Chief Operating
More informationGUIDELINES FOR INTERACTIONS OF CLINICIANS AND RESEARCHERS WITH INDUSTRY
GUIDELINES FOR INTERACTIONS OF CLINICIANS AND RESEARCHERS WITH INDUSTRY Overview The overriding goal of these guidelines is to ensure to the fullest extent possible that the integrity of clinical and research
More informationRecover Health Training. Corporate Compliance Plan Code of Conduct Fraud & Abuse
Recover Health Training Corporate Compliance Plan Code of Conduct Fraud & Abuse 1 The Course Objectives When you complete this course you will be able to: Understand Recover Health s reasons for implementing
More informationAsia Pacific Medical Technology Association CODE OF ETHICAL CONDUCT. For Interactions With Health Care Professionals
Asia Pacific Medical Technology Association CODE OF ETHICAL CONDUCT APACMed MISSION: Our mission is to improve the standards of care through innovative collaborations among stakeholders to jointly shape
More informationSTANDARDS OF CONDUCT SCH
STANDARDS OF CONDUCT SCH01242018 2018 LETTER FROM THE CEO Welcome, Thank you for choosing St. Croix Hospice. The care you provide impacts our patients, families, caregivers, and countless others every
More informationInternational Federation of Pharmaceutical Manufacturers & Associations. IFPMA Code of Practice
International Federation of Pharmaceutical Manufacturers & Associations IFPMA Code of Practice 2012 Foreword Advancing medical knowledge and improving global public health depend on information-sharing
More informationProfessional Practices Policy (P3)
Novartis Global Policy Professional Practices Policy (P3) Novartis Global Policy March 1st, 2018 Version GIC 102.V1.EN NOVARTIS GLOBAL POLICY 2 Contents 1 Introduction... 3 2 Principles... 4 3 Policy...
More informationRecent Developments in Stark and Anti-Kickback Statute Enforcement
Recent Developments in Stark and Anti-Kickback Statute Enforcement Health Care Compliance Association Regional Conference May 18, 2012 Robert Belfort Manatt, Phelps & Phillips, LLP Agenda Overview Lessons
More informationCodes of Ethics. (Version 1) June 2013
(Version 1) June 2013 Content: Page 1 Purpose. 1 2 General Principles 1 3 Definitions. 2 4 Consulting Arrangements with Healthcare Professionals 2 5 Third Party Educational Conferences 3 6 Company-Sponsored
More informationCONDUCTING A COMPLIANCE REVIEW OF HOSPITAL- PHYSICIAN FINANCIAL ARRANGEMENTS
CONDUCTING A COMPLIANCE REVIEW OF HOSPITAL- PHYSICIAN FINANCIAL ARRANGEMENTS Dennis S. Diaz Partner Davis Wright Tremaine LLP Los Angeles, California A. CMS has the Authority to Require Hospitals to Provide
More informationCompliance Program Updated August 2017
Compliance Program Updated August 2017 Table of Contents Section I. Purpose of the Compliance Program... 3 Section II. Elements of an Effective Compliance Program... 4 A. Written Policies and Procedures...
More informationGRANT AND CHARITABLE DONATIONS POLICY
GRANT AND CHARITABLE DONATIONS POLICY I. Purpose and Scope Wright Medical Technology s ( the Company ) commitment to foster charitable donations and giving, and to encourage research and education, is
More informationA 12-Step Program to Better Compliance: A Practical Approach
A 12-Step Program to Better Compliance: A Practical Approach Kim Harvey Looney Anna M. Grizzle 615.850.8722 615.742.7732 kim.looney@wallerlaw.com agrizzle@bassberry.com 11389849 Strict Government Compliance
More informationCompliance Considerations for Clinical Laboratories
Compliance Considerations for Clinical Laboratories Elizabeth Sullivan, Esq. McDonald Hopkins, LLC 600 Superior Ave., E, Suite 2100 Cleveland, Ohio 44114 P: 216.348.5401 / F: 216.348.5474 esullivan@mcdonaldhopkins.com
More informationCommunity Mental Health Center 2010 Annual Compliance Plan
Community Mental Health Center 2010 Annual Compliance Plan This is a model Compliance Plan. Please note that rules, regulations and standards change. It is strongly recommended that you verify the components
More informationFAQ FREQUENTLY ASKED QUESTIONS BUSINESS COURTESIES, GIFTS & SUPPLIER RELATIONS. A supplement to Code of Conduct
FAQ FREQUENTLY ASKED QUESTIONS BUSINESS COURTESIES, GIFTS & SUPPLIER RELATIONS A supplement to Code of Conduct Table of CONTENTS 3 6 6 7 8 9 10 11 12 Business Courtesies, Gifts and Supplier Relations Doing
More informationTo Give or Not to Give: A Comprehensive Analysis of Stark s Non-Monetary Compensation Exception
To Give or Not to Give: A Comprehensive Analysis of Stark s Non-Monetary Compensation Exception Robert A. Wade Partner Krieg DeVault LLP 4101 Edison Lakes Parkway, Suite 100 Mishawaka, IN 46545 Telephone:
More informationPhysician Referral: Laws, Rules, and Ethics
Physician Referral: Laws, Rules, and Ethics Nabil El Sanadi, MD, MBA, FACEP Chairman, Council on Ethical and Judicial Affairs, Florida Medical Association Chief of Emergency Medicine, Broward Health Clinical
More informationAHIA: Mitigating Risk through Auditing and Monitoring. Grants and Educational Activities
AHIA: Mitigating Risk through Auditing and Monitoring Grants and Educational Activities October 18, 2007 Heather J. Stewart Dir., Corporate Compliance Counsel MedImmune Disclaimer My opinions are based
More informationAdvaMed / NEMA-MITA Codes of Ethics Comparison March 23, 2009 OUTLINE
AdvaMed / NEMA-MITA Codes of Ethics Comparison March 23, 2009 OUTLINE The two Codes of Ethics are substantially equivalent and in many cases are identically the same. Following are areas of significant
More informationOMeGA Medical Grants Association RESIDENCY/CORE COMPETENCY INNOVATION GRANT RECIPIENT AGREEMENT. Order number* Program applicant name*
OMeGA Medical Grants Association 2015-2016 RESIDENCY/CORE COMPETENCY INNOVATION GRANT RECIPIENT AGREEMENT Order number* Program applicant name* This Grant Recipient Agreement is between OMeGA Medical Grants
More informationADVOCATE HEALTH CARE GUIDELINES FOR VENDOR RELATIONS
ADVOCATE HEALTH CARE GUIDELINES FOR VENDOR RELATIONS PURPOSE: To provide guidelines for ethical conduct to all Advocate Health Care associates and physicians, as well as individuals and organizations who
More informationPAYMENT AND REFERRAL RELATIONSHIPS IN HOME HEALTH: RECENT DEVELOPMENTS IN FLORIDA AND FEDERAL LAW. Craig H. Smith & Gabriel L.
HCCA 15 th Annual Compliance Institute-April 10-13, 2011 PAYMENT AND REFERRAL RELATIONSHIPS IN HOME HEALTH: RECENT DEVELOPMENTS IN FLORIDA AND FEDERAL LAW I. INTRODUCTION Craig H. Smith & Gabriel L. Imperato
More informationThe Meeting Planner s Challenge: Contending with Ever-Changing Healthcare Regulations
The Meeting Planner s Challenge: Contending with Ever-Changing Healthcare Regulations Rosaelena Bernaducci, CMP Sr. Meeting Professional & Compliance Manager Bernaducci & Assoc Disclaimer The views and
More informationUCLA HEALTH SYSTEM CODE OF CONDUCT
UCLA HEALTH SYSTEM CODE OF CONDUCT STANDARD 1 - QUALITY OF CARE The University s health centers and health systems will provide quality health care that is appropriate, medically necessary, and efficient.
More informationAbout Baptist Medical Center
About Baptist Medical Center Locally owned and operated in Jacksonville, Florida BMC includes 2 Adult and 1 Children s Hospital 960 licensed beds Disproportionate Share Hospital Recently opened Baptist
More informationMedicare Fraud Strike Force Teams Turn Up The HEAT. By Craig A. Conway, J.D., LL.M.
Medicare Fraud Strike Force Teams Turn Up The HEAT By Craig A. Conway, J.D., LL.M. caconway@central.uh.edu Federal agents have been serving warrants, conducting raids, and making arrests across Houston,
More informationApproved by: UMMG Executive Committee. Date Approved: NOVEMBER 22, 2011
UMMG Policy Interactions with Health Industry Entities Approved by: UMMG Executive Committee Date Approved: NOVEMBER 22, 2011 Medical intellectual honesty, the application of best of scientific evidence,
More informationTypes of Authorized Recipients Probation/Parole Officers or the Department of Corrections
Types of Authorized Recipients Probation/Parole Officers or the Department of Corrections Research current through May 2016. This project was supported by Grant No. G1599ONDCP03A, awarded by the Office
More informationPROPOSED REGULATION OF THE CHIROPRACTIC PHYSICIANS BOARD OF NEVADA. LCB File No. R October 3, 2005
PROPOSED REGULATION OF THE CHIROPRACTIC PHYSICIANS BOARD OF NEVADA LCB File No. R140-05 October 3, 2005 EXPLANATION Matter in italics is new; matter in brackets [omitted material] is material to be omitted.
More informationForward-thinking healthcare solutions It s what we do. Healthcare Law
Forward-thinking healthcare solutions It s what we do Healthcare Law A well-regarded firm with a sophisticated healthcare practice offering expert advice to a broad base of clients including hospitals,
More informationCompliance Program. Life Care Centers of America, Inc. and Its Affiliated Companies
Compliance Program Life Care Centers of America, Inc. and Its Affiliated Companies Approved by the Board of Directors on 1/11/2017 TABLE OF CONTENTS Page I. Introduction... 1 II. General Compliance Statement...
More informationApril, 2007 QUESTIONABLE PRACTICES BY HOSPICES AND NURSING HOMES UNDER HEALTH CARE FRAUD AND ABUSE RULES
HOSPICE AND PALLIATIVE CARE PRACTICE GROUP: Mary H. Michal, Chair Linda Dawson Meg S.L. Pekarske Matthew K. McManus LONG TERM CARE AND SENIOR HOUSING PRACTICE GROUP: Robert J. Heath, Chair Burton A. Wagner
More informationFEDERAL PROSECUTIONS OF WORKERS COMPENSATION CLINICS
FEDERAL PROSECUTIONS OF WORKERS COMPENSATION CLINICS Dr. NICK OBERHEIDEN Federal Attorney LYNETTE BYRD Former Federal Prosecutor 1-800-810-0259 Available on Weekends page 1 INTRODUCTION The U.S. government
More informationMississippi Baptist Health Systems Code of Ethics and Business Conduct
Mississippi Baptist Health Systems Code of Ethics and Business Conduct Dear Valued Baptist Associate Throughout the Baptist system we are dedicated and proud to treat our patients and conduct our business
More informationPatient Consent Form
Alexander Raskin, M.D., Q.M.E. Assistant Clinical Professor UCLA School of Medicine ORTHOPEDIC SURGERY SPORTS MEDICINE ARTHROSCOPY 16311 Ventura Blvd., Suite 1150, Encino, CA 91436 T (818) 788-ORTHO (6784)
More informationCONDUCTING A COMPLIANCE REVIEW OF HOSPITALPHYSICIAN FINANCIAL ARRANGEMENTS
CONDUCTING A COMPLIANCE REVIEW OF HOSPITALPHYSICIAN FINANCIAL ARRANGEMENTS Dennis S. Diaz, Esq. Shannon G. Dwyer, Esq. Partner Davis Wright Tremaine LLP Los Angeles, CA Sr. Vice President and General Counsel
More informationCompliance Program Code of Conduct
City and County of San Francisco Department of Public Health Compliance Program Code of Conduct Purpose of our Code of Conduct The Department of Public Health of the City and County of San Francisco is
More informationPharmacies Medicare Part D Training Obligations and Medicare Training Resources
Pharmacies Medicare Part D raining Obligations and Medicare raining Resources. Your obligation - MS regulations require that all pharmacies contracted with Medicare Part D Plan Sponsors, such as the Medco
More informationThe following ACCME Standards are particularly relevant to commercial support:
MUSC Office of CME (OCME) Policies on External Funding of CME Activities MUSC Office of Continuing Medical Education Policies on External Funding of CME Activities MUSC Office of Continuing Medical Education
More informationStrengthening Quality and Accountability for Patients Act, 2017 (Bill 160): What You Need to Know. Bill 160: Background
Strengthening Quality and Accountability for Patients Act, 2017 (Bill 160): What You Need to Know Christelle Gedeon, Associate Laurie Turner, Associate October 30, 2017 Bill 160: Background Omnibus legislation
More informationThe Orthopaedic Surgeon s Relationship with Industry
Opinion on Ethics and Professionalism The Orthopaedic Surgeon s Relationship with Industry An AAOS Opinion on Ethics and Professionalism is an official AAOS statement dealing with an ethical issue, which
More informationRUTGERS BIOMEDICAL AND HEALTH SCIENCES CODE OF CON DU CT
RUTGERS BIOMEDICAL AND HEALTH SCIENCES CODE OF CONDUCT PREAMBLE On August 22, 2012, Governor Chris Christie signed legislation into law known as the New Jersey Medical and Health Sciences Education Restructuring
More informationThe American Occupational Therapy Association Advisory Opinion for the Ethics Commission. Ethical Considerations in Private Practice
The American Occupational Therapy Association Advisory Opinion for the Ethics Commission Ethical Considerations in Private Practice For occupational therapy practitioners with an entrepreneurial spirit
More informationCode of Conduct. at Stamford Hospital
Code of Conduct at Stamford Hospital As a Planetree hospital, we are committed to personalizing, humanizing and demystifying the healthcare experience for patients and their families. Our approach is holistic
More informationCODE OF CONDUCT Q&A. Medicines for Europe. Follow us on
CODE OF CONDUCT Q&A Medicines for Europe Follow us on Rue d Arlon 50-1000 Brussels Belgium T: +32 (0)2 736 84 11- F: +32 (0)2 736 74 38 www.medicinesforeurope.com 1 Code of Conduct Q&A Contents Introductory
More informationHealthStream Regulatory Script. Corporate Compliance: A Proactive Stance. Version: [February 2007]
HealthStream Regulatory Script Corporate Compliance: A Proactive Stance Version: [February 2007] Lesson 1: Introduction Lesson 2: Importance of Compliance & Compliance Programs Lesson 3: Laws and Regulations
More informationManaged Care Fraud: Enforcement and Compliance HCCA Compliance Institute March 28, 2017
Managed Care Fraud: Enforcement and Compliance HCCA Compliance Institute March 28, 2017 Pamela Coyle Brecht, Partner Pietragallo Gordon Alfano Bosick & Raspanti, LLP Risk Area: False Data and/or Certifications
More informationLooking at our Achievements and the Way Forward. The 5 th pharmaceutical compliance congress & best practices forum Istanbul - Turkey
2005 2010 Looking at our Achievements and the Way Forward The 5 th pharmaceutical compliance congress & best practices forum Istanbul - Turkey What was accomplished since launch of MEA code in 2005? Increased
More informationFoundations Health Solutions Nursing Facility Integrity Manual Revised August 2017
Foundations Health Solutions Nursing Facility Integrity Manual Revised August 2017 T A B L E O F C O N T E N T S Our Commitment to Integrity... 3 1.0 Code of Ethics... 5 2.0 Reporting & Response (Disclosure
More informationSTANDARDS OF CONDUCT A MESSAGE FROM THE CHANCELLOR INTRODUCTION COMPLIANCE WITH THE LAW RESEARCH AND SCIENTIFIC INTEGRITY CONFLICTS OF INTEREST
STANDARDS OF CONDUCT A MESSAGE FROM THE CHANCELLOR Dear Faculty and Staff: At Vanderbilt University, patients, students, parents and society at-large have placed their faith and trust in the faculty and
More informationResponding to Today s Health Care Regulatory Environment
Responding to Today s Health Care Regulatory Environment St. Joseph s Health Michael R. Holper SVP, Compliance and Audit Services October 26, 2016 2014 Trinity Health. All Rights Reserved. 1 We operate
More informationGovernment Focus in Home Health
Government Focus in Home Health November 8, 2011 Cheryl Golden Director Deloitte & Touche LLP Contents Current Regulatory Focus in Home Health Government Programs HHS OIG Work Plan 2012 Auditing and Monitoring
More informationContent. Preamble 3. PART A Interaction with Health Care Professionals 5. I. Member-sponsored product training & education 5
CODE OF ETHICS Content Preamble 3 PART A Interaction with Health Care Professionals 5 I. Member-sponsored product training & education 5 II. Supporting third party educational conferences 6 III. Sales
More informationCORPORATE COMPLIANCE POLICY AUDIT & CROSSWALK WHERE ADDRESSED
QUALITY OF CARE Sufficient Staffing Inadequate staffing levels or insufficiently trained (inadequate clinical expertise) or insufficiently supervised staff providing medical, nursing, and related services
More informationOverlapping Surgery Developments
HCCA 21 st Annual Compliance Institute March 26-29, 2017 Overlapping Surgery Developments Alana B. Sullivan Erlanger Health System Sara Kay Wheeler King & Spalding LLP Agenda Overview of Overlapping Surgeries
More informationCode of Ethics Effective date: 02/02/2018
Code of Ethics Effective date: 02/02/2018 Ballad Health is committed to acting with integrity and ethical behavior at all times Our organization exists to meet the needs of our community, and therefore
More informationVersion 1.0. Quality, Performance & Finance. Date Ratified 31 st March 2015 Iain Stewart, Head of Direct Commissioning
Joint working with the pharmaceutical industry Policy (Template based upon DH Best Practice Guidance for Joint Working between the NHS and the Pharmaceutical Industry, February 2008) Version 1.0 Ratified
More informationRetail Clinics in Healthcare: Overcoming Complex Legal Challenges
Presenting a live 90-minute webinar with interactive Q&A Retail Clinics in Healthcare: Overcoming Complex Legal Challenges Complying With Corporate Practice of Medicine, Licensure, and Scope of Practice
More informationSponsorship of Health Workers and Institutions for Professional Development and Scientific Research
Guideline Recommended February 2017 Sponsorship of Health Workers and Institutions for Professional Development and Scientific Research Guideline Recommended February 2017 Issuing department Nestlé Nutrition
More informationSeptember 3, Dear Provider:
September 3, 2014 Dear Provider: As a contractor with Centers for Medicare & Medicaid Services (CMS), Arkansas Blue Cross and Blue Shield are required by the regulations to develop and maintain a compliance
More information1.Cultural & Linguistic Competence. 2.Model of Care for Special Needs Patients. 3.Combating Medicare Fraud, Waste and Abuse. Revised January 2017
Corporate Compliance Training: 1.Cultural & Linguistic Competence 2.Model of Care for Special Needs Patients 3.Combating Medicare Fraud, Waste and Abuse Revised January 2017 1 This training presentation
More informationDepartment of Health and Human Services. Centers for Medicare & Medicaid Services. Medicaid Integrity Program
Department of Health and Human Services Centers for Medicare & Medicaid Services Medicaid Integrity Program California Comprehensive Program Integrity Review Final Report Reviewers: Jeff Coady, Review
More informationBOARD OF COOPERATIVE EDUCATIONAL SERVICES SOLE SUPERVISORY DISTRICT FRANKLIN-ESSEX-HAMILTON COUNTIES MEDICAID COMPLIANCE PROGRAM CODE OF CONDUCT
BOARD OF COOPERATIVE EDUCATIONAL SERVICES SOLE SUPERVISORY DISTRICT FRANKLIN-ESSEX-HAMILTON COUNTIES MEDICAID COMPLIANCE PROGRAM CODE OF CONDUCT Adopted April 22, 2010 BOARD OF COOPERATIVE EDUCATIONAL
More informationBON SECOURS RICHMOND NOTICE OF PRIVACY PRACTICES
BON SECOURS RICHMOND NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFEULLY.
More information