The Pharmaceutical Compliance Forum

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NEW! Special Advisory Bulletin 

Special Advisory Bulletin
Click here to access

The Special Advisory Bulletin issued in January 2026 highlights how the federal Anti Kickback Statute applies when drug manufacturers sell prescription medications directly to patients who are covered by federal health care programs. It warns that manufacturer to patient sales can create kickback risks-especially when discounts, copay support, or other financial inducements could steer federally insured patients toward specific products. The OIG emphasizes that manufacturers must structure any direct to consumer arrangements to avoid improper remuneration and ensure compliance with federal fraud and abuse laws.


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