Linda Clark, Health Care Controversies Team leader, and Brad Gallagher, counsel, wrote a blog post called “Does Your Pharmacy’s Loyalty Program Place Your Pharmacy at Risk?” for the Pharmacy Insider. Linda and Brad note:
Rewards and customer loyalty programs have been popular means of creating customer stickiness for years. However, if you are thinking of implementing a program or already have a program, your pharmacy should be vigilant to ensure compliance with the pharmacy’s legal and contractual obligations. A failure to do so creates a risk of recoupments and terminations from PBM networks, kickback violations, and potential litigation with health plans.
Read the full post here.