Considerations for Rebooting Speaker Programs Post-Pandemic

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It’s well known that educational speaker programs have presented numerous compliance risks in the pharmaceutical and medical device industry over the past decade, as evidenced by numerous Corporate Integrity Agreements, settlements, and even prosecutions that hinge on conduct associated with speaker programs. Companies have sought to avoid the spotlight by mitigating those risks through targeted controls in order to keep these programs in play rather than remove them altogether. Meanwhile, the Office of Inspector General (OIG) has subtly, and not-so-subtly, conveyed its skepticism on the pure educational value of speaker programs in recent years. The OIG withheld formal guidance on the topic until last month, when it solidified a position on speaker programs through the issuance of a Special Fraud Alert (SFA).

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