Fraud and Abuse

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As a healthcare company, it is critical that we always do what is right for the many people we serve.

This includes complying with fraud and abuse laws and regulations that are designed to protect federal and state healthcare programs and their Patients from improper influence.

Upon the completion of this course, you will:

• Be able to explain why the US Government has a specific interest in what we do and how we do it.
• Understand the laws and regulations designed to prevent fraud and abuse in the healthcare industry.
• Understand Abbott's expectations for conducting business in the US and its territories the right way.
• Know where to go for help and support.

[1] Our Philosophy

1 minutes

[2] Introduction to Fraud and Abuse

6 minutes

[3] Laws and Regulations

10 minutes

[4] The Impact on our Business

8 minutes

[5] Your Commitment

2 minutes

[6] Knowledge Check

5 minutes

Learning Progress

This Topic is now available.

In this section, we will look at why the Government has a specific interest in protecting federal and state healthcare programs, and their Patients, from improper influence.

Let’s begin by finding out what fraud and abuse can look like in the healthcare context.

Fraud is an intentional or deliberate act to deprive another of property or money by deception or other unfair means.

It includes intentionally submitting false information to the Government (including situations in which you should have known the information was false) to get money or a benefit.

Healthcare fraud is when a person or entity seeks to deceive the healthcare system for financial gain, usually through the use of false or misleading information.

Examples of healthcare fraud:

• Double billing or over-charging
• Billing for supplies or services that were not delivered
• Offering, paying, soliciting, or receiving bribes or kickbacks (directly or indirectly) to induce referrals or the generation of business

Abuse includes actions that may, directly or indirectly, result in unnecessary costs to federally funded programs.

Abuse involves accepting payment for items or services when there is no legal entitlement to that payment.

Examples of healthcare abuse include:

• Incentivizing an HCP to buy a set of medical devices when they only need a single item in the set
• Approving billing for services not rendered
• Placing a re-order and billing for supplies, knowing that the Patient has not exhausted their supplies on hand
• Not correcting a computer glitch that resulted in Patients being billed with the incorrect billing code
• Providing materials to HCPs that promote off-label usage and/or are not consistent with applicable legal or regulatory requirements

The US Government spends trillions annually on healthcare.

The Government is the nation’s single largest healthcare purchaser, through its financing of Medicare and Medicaid programs. It also invests heavily in public health education, research and development activities, and product approval processes.

Because the Government is such a huge investor in healthcare, it wants to ensure that taxpayer funding put into the system is legitimately spent.

The Government wants to ensure that there is a legitimate need for the products and services it is paying for.

That means if an HCP orders a continuous glucose monitor or a pacemaker for a Patient, the Government wants to make sure the HCP is choosing the monitor based on what is in the Patient’s best health interests. If certain products are over-used, there may be a concern that there is not a legitimate need.

The law requires that we only market products for the purposes for which they have been approved.

This means that we must not market products for an unapproved indication or in an unapproved age group, dosage, or route of administration. For example, if a product is approved for adults 18 and older, it cannot be marketed to children.

It also requires that our sales and marketing activities avoid trying to create needs for products where none exist.

For example, we must never encourage HCPs to order diagnostic tests that are not medically necessary.

The Government also has a clear financial interest in ensuring that the price it pays for a product or service represents the true and fair cost for that product or service.

For example, if the Government is paying for stents being used in Medicare Patients, hospitals are responsible for reporting the costs of the stents they implant. The Government wants to ensure that the prices being reported accurately reflect the prices being paid and are not being distorted or hidden, for example, a discount applied to other products when it is really applicable to the stents.

Quick Check

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Because the U.S. is a private healthcare market, the government plays no role in controlling costs.

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False

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The Government is the biggest purchaser of healthcare in the U.S. and plays an active role in controlling costs.

Fraud and Abuse includes actions that may, directly or indirectly, result in unnecessary costs to federally funded programs.

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Review

Take a moment to review some of the key concepts in this section.

Government’s Interest

The Government has a specific interest in preventing healthcare fraud and abuse.

Fraud

Fraud is when a person or entity seeks to deceive the healthcare system for financial gain..

Abuse

Abuse refers to business practices and actions that are intended to result in unnecessary or inappropriate healthcare services.

Our Responsibility

As a healthcare company, it is critical that we always do what’s right for the many people we serve.

[1] Our Philosophy

1 minutes

[2] Introduction to Fraud and Abuse

6 minutes

[3] Laws and Regulations

10 minutes

[4] The Impact on our Business

8 minutes

[5] Your Commitment

2 minutes

[6] Knowledge Check

5 minutes

Learning Progress

This Topic is now available.

To protect its investment in healthcare, and the millions of Patients who receive healthcare benefits through Government programs, federal and state governments have enacted fraud and abuse laws and regulations.

As we mentioned earlier, these laws and regulations are aimed at protecting federal and state healthcare programs and their Patients from improper influence.

Abbott is subject to regulations from a variety of federal agencies, including the Food and Drug Administration, the Centers for Medicare and Medicaid Services, and the Veteran’s Affairs Administration.

Abbott also follows applicable state laws.

Failure to comply with these laws and regulations can result in stiff fines and penalties.

Because of this, you are responsible for understanding the regulations governing your area of work.

The healthcare industry has a variety of industry codes and standards that are designed to prevent fraud and abuse, and to ensure medically necessary services are delivered to Patients.

As a member of the Advanced Medical Technology Association (AdvaMed), Abbott supports the AdvaMed Code.

The AdvaMed Code provides guidance for medical technology companies on how to interact with HCPs within the scope of US fraud and abuse laws and regulations.

Code guidance is reflected in applicable Abbott policies and procedures, such as the U.S. Ethics and Compliance Policy and Procedures (USP&P), which apply to all business activities occurring within the United States and all of its territories.

The Anti-Kickback Statute is a federal law that aims to protect patients and federal health care programs by preventing fraud and abuse.

The Statute may apply even where a legitimate business need exists for an arrangement or offer, if one purpose of the arrangement or offer was to induce or reward referrals or orders.

The scope of the Anti-Kickback Statute is broad.

The law can be applied to any transaction we have with an HCP that involves providing the HCP with something of value, such as:

• Educational programs for lab technicians.
• Offering evaluation equipment to a hospital group.
• Offering a business meal to attendees at speaker programs.

Any transaction in which we offer something of value is subject to scrutiny under this law.

The Anti-Kickback Statute may apply even where a legitimate business need exists for an arrangement or offer, if any one purpose of the arrangement or offer was to induce or reward referrals or orders.

Anything of value includes:

• Payments for services
• Certain types of discounts or rebates
• Meals, travel, and entertainment
• Providing programs, advertising, or referral services

The Anti-Kickback Statute doesn’t just apply to Abbott employees.

It also applies to Abbott agents, including our Distributors.

The Federal False Claims Act is another law aimed at protecting Government interests by preventing fraud and abuse in Government healthcare programs.

The law imposes stiff penalties on companies and individuals who submit false information to the Government or cause someone else to do so.

Healthcare companies can face prosecution under the False Claims Act in many different ways,

• By submitting, cause someone else to submit, or are aware that false information is being submitted about the actual cost of the equipment, tests, and devices the Government is paying for.
• Promoting Products for Non-Approved Uses
• Engaging in Kickbacks

For example, if a healthcare company doesn’t have the medical documentation required to support a claim, but bills for it anyway, that company may be liable for submitting a false claim.

Healthcare companies can face prosecution for promoting products to HCPs for uses for which they have not been approved (e.g., for off-label uses) if the HCPs then submit claims for those products to the Government.

Abbott can only lawfully advertise our devices for the purposes for which they are approved by FDA. Advertising a device for an unapproved purpose is called "off-label promotion" and it is prohibited. However, physicians may prescribe Abbott products for unapproved uses.

Likewise, healthcare companies can face prosecution for providing illegal kickbacks to HCPs.

Items of value can be considered kickbacks if offered for an improper purpose. Even a business meal, if offered for improper reasons, can be seen as a kickback.

If, for example, an HCP receives kickbacks from a healthcare company, then claims submitted by that HCP to the Federal Government for the products made by the company, and purchased or recommended by the HCP, might be considered fraudulent.

Did You Know?

Both the party offering a kickback and the party receiving the kickback can be held responsible under the Anti-Kickback Statute and False Claims Act.

LEARN MORE

The Government regularly enforces both of these laws against HCPs and healthcare companies.

Violations of fraud and abuse laws and regulations carry a range of penalties and sanctions.

Companies can face large criminal and civil fines as well as potential exclusion from participation in federal healthcare programs, such as Medicaid and Medicare, while individuals can receive fines and even prison sentences.

CLICK FORWARD TO FIND OUT WHAT THIS LOOKED LIKE FOR ONE WELL-KNOWN COMPANY.

BIOGEN, INC.

In 2022, the international pharmaceutical company, Biogen, Inc., faced claims that it had unlawfully paid kickbacks to physicians and other healthcare professionals.

Biogen allegedly paid hundreds of healthcare professionals to speak when there was no demand for presentations and knowingly compensated its speakers and consultants at a rate significantly exceeding the fair market value for their services.

Biogen also allegedly inflated the amounts paid to most of its speakers and consultants by automatically adding three hours of travel time to their compensation, even when Biogen knew the HCPs whom it paid did not have to travel or only travelled a minimal distance.

Additionally, many of Biogen’s events were held at sumptuous resorts and restaurants, where Biogen treated its speakers and consultants to expensive meals and free alcohol.

As a result, Biogen agreed to pay $900 million to resolve the allegations.

Source: The US Department of Justice, Office of Public Affairs

The Government and other regulators take action each year to address fraud and abuse.

In 2022 alone:

• The Federal Government recovered $1.6 billion in healthcare fraud related false claims act settlements.
• The Department of Justice (DOJ) opened 809 new healthcare fraud investigations.
• Investigations conducted by HHS’s Office of Inspector General resulted in 661 criminal actions, 726 civil actions, and over 2300 exclusions from participation in Medicare, Medicaid and other Federal healthcare programs.

Quick Check

Test your knowledge now!

Giving a physician an expensive bottle of wine in hopes that they’ll purchase a product from our company may violate the Anti-Kickback Statute.

True

False

Submit

That's Correct!

That's Not Correct!

Items of value can be considered kickbacks if offered for an improper purpose.

While the company may be penalized for fraud and abuse, the individual is never penalized.

True

False

Submit

That's Correct!

That's Not Correct!

Remember that both offering and accepting kickbacks may be prosecutable under the law.

Both the company and individuals can be penalized with fines and even prison sentences.

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Review

Take a moment to review some of the key concepts in this section.

Laws and Regulations

Federal and state Governments have enacted fraud and abuse laws and regulations, including the Anti-Kickback Statute and the Federal False Claims Act.

Anti-Kickback Statute

The Anti-Kickback Statute prohibits anyone working on behalf of a healthcare company from offering, soliciting, receiving, or paying anything of value to an HCP in exchange for the purchase, prescription, recommendation, or referral of the company’s products.

Federal False Claims Act

The Federal False Claims Act is aimed at protecting Government interests by preventing fraud and abuse in Government healthcare programs.

Violations

Violations of these laws carry a range of penalties for companies and individuals, including large criminal and civil fines.

[1] Our Philosophy

1 minutes

[2] Introduction to Fraud and Abuse

6 minutes

[3] Laws and Regulations

10 minutes

[4] The Impact on our Business

8 minutes

[5] Your Commitment

2 minutes

[6] Knowledge Check

5 minutes

Learning Progress

This Topic is now available.

At Abbott, we do not inappropriately provide anything of value to anyone to get a sale or obtain any other business advantage.

Simply put, we don’t buy business. We do not buy favorable treatment from HCPs, Government Officials, or Customers through providing improper payments or other items of value.

Our business activities must never create the impression of improperly influencing a business decision or relationship.

We comply not only with each country’s laws and regulations that govern how, where, when, and to whom we are permitted to promote our products, but also with our own Abbott values.

Review Abbott’s USP&P to understand basic principles that apply to some of the most common types of interactions that take place in connection with our business.

Along with any divisional policies, procedures, and other rules applicable to your business, the USP&P can guide you in your daily activities and help you to make good, ethical decisions consistent with Abbott’s core values. Adhering to these policies and procedures is an important part of our commitment to operate with honesty, fairness, and integrity in all that we do.

If you are not able to find guidance on a particular activity, do not assume that the activity is permitted.

You must consult with your manager, OEC, and/or Legal if you are unsure whether a proposed course of action will comply with any of Abbott’s standards or applicable laws and regulations.

Visit the OEC portal and review the USP&P in the Policy and Form Library in iComply.

Abbott’s USP&P sets forth general principles regarding Abbott’s expectations for routine business interactions occurring within the US and all of its territories with groups such as HCPs, HCIs, Government Officials, Customers, Retailers, Distributors, Patients, and Consumers. It defines our expectations for conducting business the right way.

CLICK THE TRANSACTIONS BELOW TO LEARN MORE ABOUT SOME OF THE POLICIES AND PROCEDURES THAT MERIT CLOSE ATTENTION.

Meals and Refreshments

Abbott may pay for occasional meals and refreshments, modest in nature and cost as judged by local standards, in connection with legitimate educational or business purposes such as business meetings, permitted under Abbott procedures. Occasional means infrequent; not every business interaction should involve a meal or coffee. Itemized receipts are required for all meals or refreshments with HCPs, regardless of the cost.

Professional Services Arrangements

Abbott may obtain services from HCPs and other service providers to meet specific, legitimate business needs for information, services, or advice. If Abbott’s own medical experts could provide the information sought, there is not a legitimate need for the professional service agreement (PSA).

Direct and Indirect Sponsorships

Sponsorship refers to Abbott’s provision of support, consistent with local laws, regulations, and industry codes, for HCPs and others to attend Third-Party Programs, with the goal to advance science and/or improve health outcomes and Patient care.

Direct Sponsorships of HCPs are prohibited in the US. Abbott may provide Indirect Sponsorships, such as an Educational Grants to training institutions, HCIs, professional societies, or similar organizations involved in medical or scientific education.

Charitable Contributions

Abbott may provide charitable contributions of Abbott products, non-Abbott goods or equipment, or funding to organizations or entities for charitable purposes, such as improving the delivery of healthcare, increasing Patient access to healthcare technology, and humanitarian assistance.

Providing Product at No Charge

Abbott may provide Abbott products to HCPs, Customers, Patients, Consumers, and others at no charge for legitimate business purposes.

In the event of an investigation, the Government will ask questions to probe the legitimacy of nearly every transaction we engage in.

For example, in the case of an advisory board meeting that has been set up to gain expert advice on the marketing direction of a new product, they might ask:

• Does the compensation offered to participating HCPs represent fair market value?
• Have the HCPs been hired based on their academic and clinical qualifications and expertise?
• Is the meeting necessary?
• Did the company actually need the advice given?
• What did the company do with the advice?
• Are the meals modest by local standards?

Even activities that are not sales- and marketing-related may raise concerns for the Government.

This is because HCPs often have many relationships and points of contact within the industry.

Take the example of interactions with an Investigator.

An investigator who enrolls Patients in a clinical trial for Abbott may also be an Abbott Customer.

She may be receiving samples from us and may be our guest at business meals.

As a result, the Government does not differentiate between the different contexts in which we interact with HCPs.

If an HCP or Customer uses, purchases, or recommends an Abbott product, all interactions with that HCP or Customer may be subject to scrutiny.

In the case of the clinical trial, the Government wants to ensure that we chose the investigator because of her knowledge and expertise, and not because she will buy more product due to being our investigator.

The Government has also provided additional guidance in the form of "safe harbor" regulations.

The "safe harbor" regulations describe various payment and business practices that, although they may involve providing something of value to an HCP, are not treated as offenses under the statute. The “safe harbor” regulations are built into the USP&P.

SELECT THE ITEMS BELOW TO FIND OUT MORE.

Approved Practices

These regulations list certain practices (such as providing equipment rentals or paying for bona fide services) that the Government deems do not violate Medicare/Medicaid fraud and abuse laws, as long as certain criteria are met.

Narrow and Specific Criteria

What is important to understand is that these "safe harbors" are almost always narrowly defined and that they require healthcare companies to meet very specific criteria.

Remember: As an Abbott employee engaging in business interactions in the US and its territories, you must follow Abbott's USP&P, and ask questions if you have any doubts about what is allowable.

Quick Check

Test your knowledge now!

The provision of meals and refreshments to HCPs are transactions that merit close attention.

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False

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In the event of an investigation, the Government will ask questions to probe the legitimacy of nearly every transaction we engage in.

Even activities that are not sales and marketing-related may raise concerns for the Government.

Paying for a modest dinner with several HCPs to discuss the benefits of one of our company's products is a permitted activity.

True

False

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That's Correct!

That's Not Correct!

Modest and occasional dinners can be a permitted business activity, but be aware that transactions related to meals and refreshments are subject to scrutiny. There must be a legitimate business purpose for the meal.

If you're not sure whether something is permitted or subject to extra scrutiny, refer to our policies and procedures or reach out to OEC and Legal.

If an HCP or Customer uses, purchases, or recommends an Abbott product, all interactions with that HCP or Customer may be subject to scrutiny.

True

False

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If a government investigation were to occur, the Government will question the legitimacy of nearly all transactions in which we engage in regardless of whether the activities are sales and marketing related or not.

Click the arrow to begin your review.

Review

Take a moment to review some of the key concepts in this section.

Abbott’s USPP

Abbott's USP&P provides basic principles that apply to common types of interactions that take place in connection with our business. The USP&P can guide you in your daily activities and help you to make good, ethical decisions consistent with Abbott's core values.

We Don’t Buy Business

Adhering to these policies and procedures is an important part of our commitment to operating with honesty, fairness, and integrity in all that we do.

Safe Harbor

The Government has also provided additional guidance in the form of "safe harbor" regulations, which describe various payment and business practices that are not treated as offenses under the statute.

[1] Our Philosophy

1 minutes

[2] Introduction to Fraud and Abuse

6 minutes

[3] Laws and Regulations

10 minutes

[4] The Impact on our Business

8 minutes

[5] Your Commitment

2 minutes

[6] Knowledge Check

5 minutes

Learning Progress

This Topic is now available.

As an Abbott employee, there are a number of things you can do to avoid violating federal and state fraud and abuse laws and regulations.

Work Transparently

When working with individuals who are in a position to purchase, use, prescribe, or recommend our company's products, carefully consider anything that you offer that might be interpreted as an attempt to improperly influence the decision to use our products.

Report Accurate Cost Information

Never report or cause someone else to report inaccurate information about the actual costs of products and services they submit to the Government.

Always disclose all discounts and other price reductions to Customers, so that they can pass on appropriate discounts and reductions when submitting claims for reimbursement.

Use Safe Harbors for Intended Purposes

Never attempt to "legitimize" an otherwise unacceptable activity by merely renaming or categorizing the activity with the description of a practice covered by a "safe harbor."

Raise Any Concerns

If you have a question or concern about a potential fraud or abuse violation, speak to your manager.

You can also report your concern to the OEC by visiting Speak Up, a link to which can be found in the Resource page of this course.

Take a moment to confirm that you understand your responsibilities related to fraud and abuse.

I confirm that I understand my responsibilities regarding fraud and abuse, and know where to locate and review the US Policies and Procedures.

Confirm

The Knowledge Check that follows consists of 10 questions. You must score 80% or higher to successfully complete this course.

WHEN YOU ARE READY, CLICK THE KNOWLEDGE CHECK BUTTON.

[1] Abuse occurs in healthcare spending when business practices and actions are _____?

[1] Expensive, but costs are necessary.

[2] Provided to advance the well-being of communities.

[3] Purposefully designed to incur unnecessary or inappropriate healthcare services.

[4] Designed to improve people's health.

Next

Question 1: Feedback

Abuse includes actions that may, directly or indirectly, result in unnecessary costs to federally funded programs.

[2] Which of the following is an example of healthcare fraud and abuse?

[1] Inviting HCPs to a modestly priced dinner to discuss how Abbott can support their work.

[2] Providing promotional materials to HCPs that are consistent with applicable legal and regulatory requirements.

[3] Attending a conference about another company's product.

[4] Placing a re-order and billing for supplies, knowing that the Patient has not exhausted his/her supplies on hand.

Next

Question 2: Feedback

Healthcare fraud and abuse is healthcare spending that isn't based on a legitimate need (i.e., is not medically necessary).

[3] Which of the following is an example of healthcare fraud?

[1] Providing reasonable travel and accommodations for HCPs in connection with legitimate educational or business purposes.

[2] Billing for more expensive supplies than were provided.

[3] Paying a market-rate fee for a conference speaker.

[4] Hiring a physician who previously received free samples from Abbott.

Next

Question 3: Feedback

Healthcare companies can face prosecution if they submit, cause someone else to submit, or are aware that false information is being submitted about the actual cost of the equipment, tests, and devices the government is paying for.

[4] Which of the following may not be permitted under the Anti-Kickback Statute?

Check all that apply.

[1] Payments for unnecessary services.

[2] Business opportunities that are not commercially reasonable.

[3] Providing evaluation equipment to a hospital.

[4] Giving a gift card to a physician to encourage a sale.

Next

Question 4: Feedback

The Anti-Kickback Statute may apply even where a legitimate business need exists for an arrangement or offer, if any purpose was to induce or reward referrals or orders.

[5] When may Abbott provide charitable contributions of Abbott products?

Check all that apply.

[1] To improve the delivery of healthcare.

[2] To increase Patient access to healthcare technologies.

[3] To influence physicians' medical decisions.

[4] To provide humanitarian assistance.

Next

Question 5: Feedback

Abbott may provide charitable contributions of Abbott products, non-Abbott goods or equipment, or funding to organizations or entities for charitable purposes, such as improving the delivery of healthcare, increasing Patient access to healthcare technology, and humanitarian assistance.

[6] Which of the following may be prosecutable under the False Claims Act?

[1] Billing for a claim you lack the medical documentation to support.

[2] Submitting exaggerated costs for equipment the Government is paying for.

[3] Promoting a product for a use that has not been approved by the FDA.

[4] All of the above.

Next

Question 6: Feedback

The law imposes stiff penalties on companies and individuals who either submit false information to the government or cause someone else to do so.

[7] Which of the following is true about the consequences of fraud and abuse?

[1] Failure to comply with laws and regulations can lead to significant penalties for both companies and individuals.

[2] The party receiving a kickback cannot be prosecuted under the Anti-Kickback Statute.

[3] While companies can face large criminal and civil fines, individuals are not held accountable for violating fraud and abuse laws and regulations.

[4] The Anti-Kickback Statute only applies to Abbott employees, not our distributors and other agents.

Next

Question 7: Feedback

Companies can face large criminal and civil fines as well as potential exclusion from participation in federal healthcare programs, such as Medicaid and Medicare, while individuals can receive fines and even prison sentences.

[8] Suppose you're unsure whether a business activity would qualify as fraud or abuse. Which of the following should you NOT do?

[1] Refer to Abbott's US Policies and Procedures.

[2] Proceed with the activity, because it involves a small dollar amount.

[3] Reach out to the Legal Division.

[4] Speak with your manager.

Next

Question 8: Feedback

Refer to the resources identified in answers 1, 3, and 4. The dollar amount of the transaction does not matter.

[9] Suppose you are negotiating with the purchasing manager of a hospital about the purchase of vascular devices and equipment for the hospital’s heart failure center. The manager has requested a bulk discount, which is outside Abbott’s current discount guidelines. What should you do?

[1] Suggest that instead Abbott could prove the hospital with 10 laptops free of charge – all of which will be pre-loaded with the latest software to support the vascular devices.

[2] Promise to provide a similar discount on a future order instead.

[3] Tell the manager we would find a way to structure the agreement to hide the value of the discount.

[4] None of the above.

Next

Question 9: Feedback

When working with individuals who are in a position to purchase, use, prescribe, or recommend our company's products, carefully consider anything that you offer that might be interpreted as an attempt to improperly influence the decision to use our products.

10

Suppose you are an account manager and are meeting with the purchasing manager of a large pharmacy chain to discuss the pharmacy beginning to stock Abbott’s continuous glucose monitor. The purchasing manager asks if you would pay him 15% for every Customer he can switch to your product. Is this permitted?

[1] No. Abbott does not inappropriately provide anything of value in order to obtain a business advantage.

[2] Yes. Paying sales commissions is permitted under the safe harbor regulations.

[3] Yes. However, the arrangement with the purchasing manager must be spelled out in a written contract signed by both parties.

[4] Yes. As long as the purchasing manager is not a licensed HCP who can write a prescription for the product, it is appropriate to pay a switching fee.

Submit

Question 10: Feedback

Any transaction in which we offer something of value is subject to scrutiny under Anti-Kickback Statute.

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Where to Get Help

Manager

If you have a question or concern about a potential fraud or abuse violation, speak to your manager.

Written Standards

• For our company's fundamental set of expectations about interactions with others, consult our Code of Business Conduct.
• Consult Abbott's U.S. Ethics and Compliance Policy and Procedures (USP&P) for guidance on interactions with HCPs and other groups including Healthcare Institutions (HCIs), Government Officials, Customers, Retailers, Distributors, Patients, and Consumers.
• Visit iComply: Click here for the policy and form library to access Abbott's worldwide standards.

OFFICE OF ETHICS AND COMPLIANCE (OEC)

The OEC is a corporate resource available to address your compliance questions or concerns, including fraud and abuse issues.

• Visit Compliance Contacts in iComply.
• Visit our multilingual Ethics and Compliance Speak Up Helpline available globally 24/7 to voice your concerns about potential fraud and abuse issues.
• You can also email investigations@abbott.com.

Legal Division

If you have questions about laws and regulations that govern our relationships with Customers and Business Partners, the Legal Division can assist you. Click here to access the Legal home page on Abbott World.

Course Resources

Transcript

Click here for a full transcript of the course

Our Philosophy

Fraud and Abuse

Our Philosophy

Objectives

TOC

Introduction to Fraud and Abuse

Fraud and Abuse in the Healthcare Industry

The Government’s Role

Legitimate Need

Regulating How We Market and Sell

Financial Interest in Pricing

Quick Check

Review

TOC

Laws and Regulations

Protecting Government Spending

Overview

Industry Standards

The Anti-Kickback Statute

The False Claims Act

Legal Consequences

Investigations and More

Quick Check

Review

TOC

The Impact on our Business

We Don’t Buy Business

Abbott’s US Policies and Procedures

Government Scrutiny

Safe Harbor

Quick Check

Review

TOC

Your Commitment

What You Can Do

Your Commitment

Knowledge Check

Introduction

Assessment

Feedback

Survey

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Fraud and Abuse

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Course Description: As a healthcare company, it is critical that we always do what is right for the many people we serve. This includes complying with all applicable laws and regulations.   In this course, employees will learn how to comply with fraud and abuse laws and regulations designed to protect federal and state healthcare programs and their patients from improper influence. This course will take approximately 35 minutes to complete. 

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