The lifeblood of the successful pharmacy is a continuous flow of patients: Repeat patients and new patients. New patients come to the pharmacy in different ways: Response to advertisements; word of mouth: and referrals from physicians and other health care providers. It is important for the pharmacy to build a strong network of referral sources. This network can be comprised of physicians, home health agencies, hospitals, DME suppliers, and other providers. It is perfectly legal for the pharmacy to receive referrals so long as the pharmacy does not provide “anything of value” back to the referral source. However, when the pharmacy and the referral source are involved in an arrangement that directly or indirectly benefits the referral source, then the parties need to be careful. There are multiple federal and state anti-fraud laws that govern relationships between health care providers, when one of the providers is a referral source. This program will discuss the applicable laws, including the federal anti-kickback statute; the federal Stark physician self-referral statute; the federal beneficiary inducement statute; and an example of state anti-fraud statutes. The program will discuss (i) the types of arrangements with referral sources that fall within statutory exceptions and “safe harbors” and are, therefore, safe; and (ii) the types of arrangements that need to be avoided. Specific examples of arrangements to be discussed are (i) Medical Director Agreement with a physician; (ii) Preferred Provider Agreement with a physician, hospital, or other referral source; (iii) the provision of EHR software to a long-term care facility; (iv) the provision of gifts, meals and educational programs to physicians and other referral sources; (v) subsidizing a physician’s expenses to attend a continuing education conference; and (vi) paying a physician to speak at an education program sponsored by the pharmacy.

• The attendee will understand the federal and state anti-fraud laws that govern relationships between pharmacies, and physicians, and other referral sources • The attendee will know the arrangements with referral sources that are legally acceptable

• The attendee will know which arrangements with referral sources to avoid

• The attendee will understand the mechanics of setting up certain arrangements with referral sources