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CONNAUGHT ASKED TO HALT "VIP" VACCINE MARKETING PROGRAM

Executive Summary

CONNAUGHT ASKED TO HALT "VIP" VACCINE MARKETING PROGRAM in a May 9 letter from the HHS Inspector General. "We suggest that you take steps immediately to discontinue your program in order to minimize any liability you may be incurring under the federal antikickback statute" of the Social Security Act, the letter states. The HHS Inspector General compared Connaught's vaccine marketing program to "the supermarket green stamp programs of the past." The letter states: "As we understand your program, each time one of your customers purchases a vaccine package, the customer earns a certain number of points based on a value system established by your company. After a sufficient number of points are accumulated, the customer can redeem them for a variety of items such as videocassette recorders, personal computers or TV monitors." A Connaught spokesperson said that the company is reviewing the HHS letter and feels the program is in compliance with federal law. The company added that it is "looking forward to the opportunity" to provide information regarding the program to the Inspector General. HHS pointed out that such payments or offers of anything of value used to induce sales for items reimbursed under Medicare or Medicaid are prohibited by the federal antikickback statute. Furthermore, the letter points out, "It seems clear to us that your program involves the offer of something of value intended to induce purchasers of vaccine products to buy from your company because you offer points which can be turned in for cash or consumer products." It is probable, the Inspector General continued, "that at least some of your products are provided to patients who are beneficiaries of Medicare or Medicaid, and, in those instances, would be in violation of the federal antikickback law." Connaught started the VIP campaign early this year to cut vaccine costs and to provide an office-based program for patient education, the spokesperson said. The program is geared toward pediatricians who can exchange "credits" for either a cut in vaccine costs or high-tech equipment, such as computer hardware and software, in connection with the office-based patient education program, the firm explained. The education program uses the equipment to teach physicians how to keep patient vaccine records, for example, or how to inform patients about vaccines, among other topics.
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