Hcp Consulting Agreement

Hcp Consulting Agreement

We often consider delivery contracts to be part of a product purchase agreement. Often, the HCP that executes the agreement is not aware of the component of the shipment and has not verified whether the shipment was necessary or feasible, nor has it verified the agreement to confirm the existence of safeguards such as inventory management, on-site access and product return. In order to comply with AKS` safe harbor, HCPs should enter into written agreements with companies to purchase products, including products sold on-air. These agreements should include the terms set out in the updated code. [1] Revised and Restated AdvaMed Code of Ethics on Interactions with U.S. Health Care Professionals, Advanced Med. Tech. Ass`n, www.advamed.org/sites/default/files/resource/advamed_u.s._code_of_ethics_final_-_eff._jan_1_2020.pdf (hereafter referred to as “code”). The current version of the code, which is in effect until December 31, 2019, is available on the following link: www.advamed.org/sites/default/files/resource/112_112_code_of_ethics_0.pdf.

[2] Code to 2. For clarity, all offers cited in this warning refer to the updated code, unless otherwise stated. [3] Id. to 3 [4] The provisions of the code that have not changed from the current version include the points of education and patient performance; Clinical studies and research arrangements (although now in narrative form and not only in “frequently asked questions”); Banning gifts banning entertainment and leisure activities; Travel and Accommodation; and the location of the event. While we have not included these areas of the code in this summary, HCPs should ensure that agreements with companies are also consistent with these guidelines. [5] Code at 8 [6] Id. [7] Examining the relationship between the medical device industry and physics, Testimony of Gregory E. Meske, Assistant Inspector General Affairs, OIG, DHHS, February 27, 2008 (“Meske Testimony”), oig.hhs.gov/testimony/docs/2008/demske_testimony022708.pdf.

[8] Id. to 2 [9] See z.B. Medical Equipment Company Will pay $646 million for illegal payments to doctors and hospitals in the United States and Latin America, U.S. DEP`T OF JUST. (March 1, 2016), www.justice.gov/opa/pr/medical-equipment-company-will-pay-646-million-making-illegal-payments-doctors-and-hospitals (describes a comparison by Olympus, which focuses in part on illegal payments to doctors and hospitals for equipment consulting agreements); see also Meske Testimony, p.


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