On 10 February, White & Case LLP published Part II of a 2-part series saying that one of the most important risks to explore is whether the US government might contend that any arrangements involve kickbacks in violation of the Anti-Kickback Statute. Particularly in the context of digital health, such kickback risk could be non-obvious. It says that there are 3 types of potential kickbacks: kickbacks to patients; kickbacks to healthcare providers (and other decision-makers); and kickbacks to the technology company. Part I says that healthcare enforcement can lead to significant criminal and civil penalties.
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