79378 ABFC Health Lawyer
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THE ABA HE ALTH L AW SECTION HEALTH LAWYER THE Volume 15, Number 2 December 2002 Daniel Higgins Paul, Hastings, Janofsky & Walker LLP San Francisco, CA Introduction It takes two to tango. When HHS released its draft “Compliance Program Guidance for Pharmaceutical Manufacturers”1 on September 30, 2002 (“Guidance”), pharma companies were put on notice that a comprehensive array of marketing incentives and other sales strategies would be put under OIG’s microscope. So are hospitals, health systems...