Lessons on Compliant Speaker Programs From the OIG’s Life Sciences Fraud Alert

Speaker programs can be opportunities – or cover – for illegal payments to health care providers, recent FCPA settlements have shown. The November 2020 Special Fraud Alert issued by the Office of the Inspector General of the Department of Health and Human Services focuses on fraud and abuse risks associated with speaker programs sponsored by life sciences companies, which may include violation of domestic anti-kickback laws and, when foreign officials are involved, the FCPA. We analyze the Alert and provide tips for designing compliant speaker programs with input from government officials and private practitioners. See “Novartis and Subsidiaries Settle FCPA Cases for $346M, Avoiding a Monitor Despite Recidivism” (Jul. 8, 2020).

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