Can a pharmaceutical manufacturer provide free items or services to financially needy Medicare and Medicaid beneficiaries without running afoul of the Beneficiary Inducements Civil Monetary Penalty (CMP) or the Anti-Kickback...more
2/11/2019
/ Advisory Opinions ,
Anti-Kickback Statute ,
Beneficiary Inducement ,
Digital Health ,
Low-Income Issues ,
Medicaid ,
Medical Devices ,
Medicare ,
OIG ,
Patient Assistance Programs ,
Pharmaceutical Industry
It has been one year since the U.S. Supreme Court’s landmark ruling in Universal Health Services v. United States ex rel. Escobar, which resolved a circuit split as to the validity of the implied false certification theory...more
9/21/2017
/ Conditions of Payment ,
False Claims Act (FCA) ,
False Implied Certification Theory ,
Federal Contractors ,
Health Care Providers ,
Healthcare Fraud ,
Implied Certification ,
Materiality ,
Medicaid ,
Motion to Dismiss ,
SCOTUS ,
Universal Health Services Inc v United States ex rel Escobar ,
Unlicensed Medical Providers