Marketers and sales representatives who worked with compounding pharmacies are also under intense federal government scrutiny. The government has focused on several fact patterns, including:
- Marketers and sales representatives who enrolled physicians and medical providers into speaker programs;
- Marketers and sales representatives who hired physicians and medical providers as medical directors; and
- Marketers and sales representatives who received percentage-based commissions from compounding pharmacies.
- Marketers who engaged in direct marketing to Tricare beneficiaries, and who steer these Tricare beneficiaries to select doctors; and
- Marketing agents who use “mass marketing” call centers and/or telemedicine companies. The government closely scrutinizes arrangements whereby telemedicine doctors receive a flat fee for every patient who receives a compounded pain or scar cream.
Did you Market or Distribute Pain Cream?
If you are a marketer or sales representative who was involved in the distribution of compounded pain or scar cream, then it is critical to retain attorneys who understand the complex world of compounding pharmacies and who have extensive experience in defending federal health care fraud investigations.
Free Consultation: Call us Today at (305) 371-9686
The attorneys at Stumphauzer & Sloman have defended numerous marketing companies and individual marketers in compounding pharmacy investigations, and we understand the specific facts patterns that often lead to government scrutiny. We understand the nuances of the Anti-Kickback Statute and other federal health care laws, and can help you formulate a comprehensive and tailored defense strategy.