Pharmacy Immunizers and Co-Pay/Deductible Waivers

In a Pharmacy Times magazine article, Ned Milenkovich, co-chair of the firm’s Health Care group, notes that pharmacy providers are often tempted to waive co-pays or deductibles when administering immunizations and explains that providing waivers may violate fraud and abuse laws and/or commercial contract payer terms. In particular, Ned points to the financial and other risks faced by pharmacist immunizers who run afoul of the federal Anti-Kickback Statute (AKS) and the federal Civil Monetary Penalties Law (CMPL).