OIG Pharma Guidance: The Impact on CME

In April, the Office of Inspector General released its Final Compliance Program Guidance for Pharmaceutical Manufacturers, designed to help drug and device firms comply with federal antikickback laws and other fraud and abuse statutes. One of the areas the guidance addresses is education grants, and there are major implications for firms’ relationships with continuing medical education (CME) providers.

First, the good news: Unlike the draft guidance, which made no distinction between

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