Advisory Opinions Serve as a Reminder that Arrangements Must Be Carefully Structured

05 April 2011 Publication
Authors: Lawrence W. Vernaglia

Journal of Health Care Compliance

Foley Partner Lawrence Vernaglia and Senior Counsel Lawrence Conn authored an article that appeared in the March/April 2011 issue of the Journal of Health Care Compliance titled "Advisory Opinions Serve as a Reminder that Arrangements Must Be Carefully Structured." The authors discuss marketing arrangements between health care providers and third parties who assist in advertising, stating that such arrangements need to be carefully structured because some forms of marketing may involve recommendations that are prohibited by the anti-kickback statute. They add that careful analysis, planning and external fair market value review can help to establish compliance safeguards that protect a marketing arrangement from risk of liability under the anti-kickback statute.

Related Services

Insights

Bad Holiday Season News! Estimates of an increase of Cyberattacks 20%!
13 December 2019
Internet, IT & e-Discovery Blog
Driving the Future of Automotive Technology
12 December 2019
Manufacturing Industry Advisor
Massachusetts Governor Proposes Facility Fee Ban
12 December 2019
Health Care Law Today
American Rule Prevails; PTO May Not Collect In-House Attorneys' Fees as "Expenses"
12 December 2019
IP Litigation Current
ACCC 46th Annual Meeting & Cancer Center Business Summit
04-05 March 2020
Washington, D.C.
Foley/Deloitte Compliance and Privacy Officer Roundtable
27 February 2020
Boston, MA
Let’s Talk Compliance
24 January 2020
Orlando, FL
New England Alliance Annual Meeting
15-17 January 2020
Woodstock, VT