Compliance, Ethics, and Fraud for Sales Professionals

Table of Contents:

• Compliance, Ethics, and Fraud
• Legal Notice
• Purpose and Learning Objectives
• Target Audience
• Compliance and Ethics in Health Care
• Mandatory Compliance
• Effective Compliance Program
• Components of an Effective Compliance Program
• Ethical Business Practices: Interactions with Health Care Professionals
• Integrity, Independence, Transparency
• Federal Health Care Fraud and Abuse Laws
• False Claim Act (FCA)
• Anti-Kickback Statue (AKS)
• Stark Law
• Exclusion Statue
• Summary
• End of Course Quiz

Course Content Example 1:

 Integrity, Independence, Transparency

The Department of Health and Human Services, Office of the Inspector General (OIG) mandates ethical business practices.

Companies must:

• Ensure the collaborative relationships with health care professionals meet high ethical standards
• Relationships must be conducted with appropriate transparency and in compliance with applicable laws, regulations and government guidance.
• Medical decisions must be based on the best interests of the patient
• Not provided inappropriate inducements to health care professionals of any monetary value, including gifts, entertainment, commissions or gratuities.
• Ensure that promotional and marketing materials on drugs or devices must be based on scientific evidence and not false information.

Course Content Example 2: 

Integrity, Independence, Transparency

Prohibition of Gifts

Provide only items to Health Care Professionals (HCPs) that benefit patients or serve a genuine educational function for HCP.

• Other than medical textbooks or anatomical models, any item should have a fair market value of less than $100.00

Non-Educational branded promotional items may not be given, even if minimal value.

• No cookies, wine, flowers, chocolates, gift baskets, holiday gifts, cash or cash equivalent may be given

Course Content Example 3:

Components of an Effective Compliance Program

1. Commitment by the organization's senor leadership for an effective compliance and ethics program.
2. Policies and Procedures. Written standards and procedures to reduce criminal, civil, and administrative violations.
3. Should be tailored to fit specific risk assessment conducted by your organization to identify risk areas faced in the healthcare arena.
4. Chief Compliance Officer. A high-ranking individual in the organization should be designated responsible for the compliance program.
5. The officer should possess resources and authority to implement the program and should report to the senior leadership of the company.