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HHS IG considers service of monetary value to be remuneration, IG branch chief McAnaney warns.

Executive Summary

HHS IG CONSIDERS SERVICE OF MONETARY VALUE AS REMUNERATION, OIG Industry Guidance Branch Chief Kevin McAnaney warned at the May 20 Food and Drug Law Institute conference in Washington, D.C. The OIG considers any gift of service from a manufacturer a prosecutable action "regardless of what the services are. If they have monetary value, then they are classified as remuneration," McAnaney said. "If a supplier or manufacturer is basically providing that service to them, at no cost to them, we think that is double-dipping, and that is basically a discount."
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