JD Supra June 28, 2023
Corporate compliance programs in the healthcare industry include many of the same elements that we are all familiar with – risk assessments, code of ethics, written policies and procedures, comprehensive training requirements, confidential reporting and investigation systems to address employee concerns, gifts, meals, grants, and medical education programs, and audit and review processes to maintain a continuous improvement program.
Aside from this standard list of requirements, there are a number of specific risks that typically have to be addressed:
Physician Interactions: Healthcare companies that fall under the broad definition of “federal healthcare programs” (e.g. Medicare, Medicaid) have to ensure they avoid risks created by the Anti-Kickback Statute, the Stark Law governing physician interests and referrals, and payments to physicians that...
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