Life Science Compliance Update Helping the Patient – Co-Pay Reimbursement Can Be Okay in Certain… Thomas Sullivan Oct 31, 2016 0 The OIG’s recent Advisory Opinion suggest that under certain circumstances patient co-pay reimbursement programs are allowable.…
State Policy California to Allow Experimental Drug Treatments for Terminally Ill… Thomas Sullivan Oct 28, 2016 0 California Governor Jerry Brown recently signed legislation allowing terminally ill patients in his state to have access to…
Life Science Compliance Update The Blue Ribbon Panel Raises the Bar on Ethics & Compliance Thomas Sullivan Oct 28, 2016 0 According to the Ethics & Compliance Initiative (ECI), ethics and compliance programs should not be “check the box programs”…
Congress Representative Lieu Laser-Focused on Device Act, Olympus Thomas Sullivan Oct 27, 2016 0 Olympus Corp. has had its fair share of legal troubles, some of which culminated in a settlement of $646 million in early 2016.…
Life Science Compliance Update Like Taxes and Inflation – HHS Revises Civil Monetary Penalties… Thomas Sullivan Oct 27, 2016 0 The Department of Health and Human Services has issued an Interim Final Rule, adjusting for inflation the maximum civil monetary…
CMS CMS Bundled Payments for Care Improvement Evaluation Released Thomas Sullivan Oct 26, 2016 0 The first year of CMS' voluntary Bundled Payments for Care Improvement initiative has yielded a mixed bag of results, according to…
Life Science Compliance Update BMS Settles with California Insurance Commission – Seems Everyone Is… Thomas Sullivan Oct 26, 2016 0 Life sciences companies continue to be the target of whistleblower actions, not only on the federal level but the state level as…
Uncategorized FDA Raises Issue of Citizen Petitions Thomas Sullivan Oct 25, 2016 0 In August, the FDA noted its concerns that citizen petitions do not raise valid scientific issues and are used to delay the…
Congress House Ways and Means Subcommittee on Oversight Holds Hearing on Health Care… Thomas Sullivan Oct 24, 2016 0 On Wednesday, September 28, 2016, the House Ways and Means Oversight Subcommittee held a hearing on Health Care Fraud…
Life Science Compliance Update How Realistic is the Yates Memo after Acclarent? Thomas Sullivan Oct 24, 2016 0 There has been much hubbub around the Yates Memorandum and what it means for compliance officers, especially in the life sciences…