Pharma’s Quiet Risk: Your Telehealth Program May Be Illegal
When people think of kickbacks, they imagine envelopes under tables and not cloud-based platforms selling digital ads and scheduling tools. But Advisory Opinion 25-03 shows how gray it really gets. A management company may lease doctors and provide services like marketing, billing, and tech platforms to a separate physician practice. That practice uses its insurance […]
When Patient Assistance Becomes a Legal Minefield
For two decades, OIG guidance has warned that manufacturer-run Patient Assistance Programs are high-risk under the Anti-Kickback Statute. Directly covering Medicare co-pays for your own drug? Red flag. Funding a “charity” that only helps patients on your product? Still risky. The 2005 OIG Special Advisory Bulletin outlined safe harbors—donate only to truly independent charities, keep […]
