“EVERYONE'S AFRAID,” says Janice Miller, director, CME, Brown Medical School, Providence, R.I. “Pharmaceutical companies have their legal departments working overtime to protect themselves from the threat of a huge, multibillion-dollar fine. I don't know if that was the intent of the OIG [Office of Inspector General's Compliance Program Guidance for Pharmaceutical Manufacturers], but that's the result.”

And they have reason to be afraid. In just this past year the industry has

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