The Physician Payment Sunshine Act puts pharmaceutical and medical device companies under intense scrutiny and exposure. Compensation paid to healthcare professionals ("HCP") and healthcare institutions for various services, such as speaking, training, product development, R&D, advisory board service and consulting must be at fair market value ("FMV") or risk being in violation of the Federal Anti-Kickback Statute. It is paramount to know and remember that FMV compensation is for a specific service, not a specific professional. Therefore, it is essential to match the qualifications and experience of the HCP providing the service to the specific service/task itself. Healthcare … [Read more...]
