Kickback and Physician Self-Referral

Kickback and self-referral violations increasingly are being pursued by the Office of Inspector General.  These are increasingly wide-reaching to cover a number of service providers, vendors, and business relationships.  In Q4 of 2013 it was reported that Henry Schein, Inc paid over $1.1 million for an alleged violation entailing remuneration to customers who were part of the Henry Schein Medical Privleges Program.  This was an alleged violation of the Civil Monetary Penalties Law provisions applicable to physician self-referrals and kickbacks. The points redeemable for products and services were allegedly not qualified as "discounts" or "rebates" under the anti-kickback statute.