Offering "Value-Added" Services to Patients While Avoiding Prohibited Inducements

An important way for a pharmacy to set itself apart from its competitors is to offer services to existing and prospective patients—services that other pharmacies do not offer. And with the recent relaxation of the federal anti-kickback statute, the federal physician self-referral statute, and the federal beneficiary inducement statute, CMS and the OIG are encouraging the provision of “value-added” services to patients. At the same time, it is important that the pharmacy not go so far that it inadvertently violates these statutes.

This program will discuss (i) the federal laws governing value-added services to patients; (ii) those value-added services that are legally acceptable; and (iii) those value-added services that may trigger a government enforcement action.

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