Originally published in the Health Care Fraud Report, 17 HFRA 219, on 03/06/2013.
The final rule (the ‘‘Final Rule’’) implementing the Physician Payments Sunshine Act (‘‘Sunshine Act’’), published in the Federal...more
In the view of the FTC and the Justice Department, competing health care providers can contract jointly with third-party payers only if the providers integrate clinically (or financially) so that gains in efficiency and...more
Legitimate joint marketing and selling arrangements have the potential to produce efficiencies. This is particularly so, for example, where the arrangement enables the participants to make or market products that they could...more
Trade and professional associations (“associations”) frequently sponsor joint purchasing arrangements on behalf of their members. These programs offer numerous potential benefits, including centralized ordering, volume...more
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