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Signatory companies submit annual certifications attesting that they have policies and procedures in place to foster compliance with the Code.
Undoubtedly in response to OIG's November 2020 Special Fraud Alert: Speaker Programs issued, on August 6, 2021, PhRMA issued a statement addressing an update to the PhRMA Code on Interactions with Health Care Professionals...
In Short The Situation: The U.S. Department of Justice ("DOJ") published its annual report regarding False Claims Act ("FCA") recoveries for fiscal year 2020 (ending September 2020) and announced its priorities for 2021. The Result: DOJ's 2020 FCA recoveries totaled more than $2.2 billion, a lower sum than in prior years. Despite the lower overall recoveries, health care fraud still represents the lion's share of FCA recoveries, encompassing cases relating to pharmaceuticals, providers, electronic health records ("EHR"), and opioids. COVID-related cases did not figure significantly in the 202...
aaaa Notable CIAs and Trends Amendments. Like the number of CIAs, the number of CIA amendments also increased in 2020. Although the HHS-OIG typically enters into one or two amendments per year, 2020 saw seven such agreements. One amendment postponed the CIA’s effective date to account for the demands of the pandemic and another added a party to account for corporate restructuring. One aa highlighted the HHS-OIG’s close review of compliance programs, adding additional compliance obligations to address concerns regarding patient safety issues and CIA adherence. The majority of amendments (f...