Please review a special alert regarding pharmaceutical and medical device-sponsored speaking engagements.
The Office of Inspector General (OIG) released a Special Alert regarding pharmaceutical and medical device-sponsored speaking engagements. The OIG and the Department of Justice (DOJ) have investigated several cases in which the remuneration offered and paid in connection with the speaking event violated the federal anti-kickback statute.
The anti-kickback statute makes it a criminal offense to knowingly and willfully solicit, receive, offer, or pay any remuneration to induce or reward, among other things, referrals for, or orders of, items or services reimbursable by a Federal health care program. When remuneration is paid purposefully to induce or reward referrals of items or services payable by a Federal health care program, the anti-kickback statute is violated.
Please carefully review the special alert and familiarize yourself with these issues.
Also, as a reminder, before you engage in an external activity, you are required to submit a “Notice of Intent” on the University’s AIR site. If you are seeking permission to engage in a speaking event, you are required to provide detailed information about the content and verify compliance with the SOM and UNC Health’s Vendor Relations Policy (see section F for specific guidelines on speaking engagements). More information about external engagements can be found here.