The Compliance Program "Effectiveness Bar" Has Just Been Raised
On September 27, 2007, the Department of Justice announced that five leading orthopedic device manufacturers avoided criminal prosecution over alleged kickbacks paid to physicians by agreeing to far reaching, invasive, and highly structured compliance and monitoring requirements. These Deferred Prosecution Agreements (and one Non Prosecution Agreement) and recent OIG Corporate Integrity Agreements contain first-of-their-kind compliance requirements that will have broad industry implications.
In addition to a federal monitor assigned to each of these companies, these settlement agreements require the implementation of formal procedures and safeguards to ensure that all consulting agreements reflect fair market value payment for bona fide services based on determined need. While Deferred Prosecution Agreements (DPAs) are becomming a common tool to resolve health fraud cases, these agreements could have profound impact on the way both medical device and pharmaceutical managed their physician consulting relationships.
Our RADSSM application is designed specifically to provide
these compliance safeguards. Avoid federal monitors and onerous integrity agreements, contact us today for a free consultation.