I am pleased to share that the AdvaMed Board of Directors has approved revisions to the AdvaMed Code of Ethics on Interactions with Health Care Professionals (HCPs) in the U.S., effective June 1, 2022.
The longstanding Code provides important guidance to medical technology companies, and with these revisions, AdvaMed and its members reaffirm their commitment to ethical and compliant interactions and collaborations with HCPs, while also ensuring that the Code reflects the evolving legal, regulatory, and health care landscape.
The revised Code includes updates concerning value-based or outcomes-based health care arrangements, consistent with the recent value-based safe harbor modernizations under the federal Anti-Kickback Statute, as well as revisions and FAQs in response to the OIG’s 2020 Special Fraud Alert on Speaker Programs.
Key Code Updates
In particular, the Code has been revised to:
- More accurately acknowledge the unique ability and role of medical technology companies to leverage health care data and technology to provide solutions – both clinical and business – to improve health care and ensure innovative and cost-effective care;
- Discuss interactions with HCPs relating to value-based care arrangements (aka results-based, outcomes-based, or performance-based arrangements), recognizing that such arrangements and collaborations lead to improvements with respect to quality of, access to, and cost of patient care;
- Address virtual interactions, meetings, and programs; and
- Provide guidance with respect to alcohol at Company-conducted programs and meetings.
In anticipation of the June 1, 2022 effective date, AdvaMed will be developing tools for stakeholders – particularly small companies – to implement these updates.
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