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  "documentTitle": "Harmony Biosciences (HRMY)",
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  "presentationDate": "2023-03-28 00:00:00",
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  "notes": "The slide uses a Q&A format to document testimony regarding corporate fraud and off-label promotion.",
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      "text": "Can you possibly stretch? Can you possibly make excessive sleepiness narcolepsy? Can you possibly make it cataplexy? Can you possibly do that?",
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      "text": "Q: “You'd observe them sending in these bullshit referrals. What would you do? Would you get some of those through the system? Were you getting pressure from Harmony? Harmony's incentive is the same as the rep, right?”\nA: “There were a number of times when it was off-label, and whenever we provided that insight, for example, the sales reps would realize I've got so many referrals. These referrals came in. So, they would come to me and say, \"What happened to these referrals?\" Okay, [redacted] gave me four referrals last month and five referrals before that. Whatever happened to those?\" Well, in this particular case, at least two referrals out of five were off-label. \"What do you mean they're off-label?\" \"They were off-label, excessive sleepiness. That's not an indication supported for this drug.\" Now, what does the sales rep do with that information? Did they go back in and say, \"Can you possibly stretch? Can you possibly make excessive sleepiness narcolepsy? Can you possibly make it cataplexy? Can you possibly do that?\" Now, did they do that with that information of the insights I was giving to them? I don't know. But they certainly have the incentive to do that.” – Ex-field reimbursement manager working with Harmony",
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      "text": "Reps were using information on referral forms to push through off-label prescriptions by faking the indication",
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      "kind": "paragraph",
      "text": "Reimbursement staff eventually figured out the company strategy behind the alleged fraud",
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      "text": "Q: “So, they were basically asking for information in a way that technically might not violate the law but would help them figure out—”\nA: “The idea is they could potentially go in and re-educate the office on re-evaluating the signs and symptoms. Honestly, I could never wrap my head around why and then one of my peers said, \"Dumbass, this is why. Don't you think they're doing that?\" And it's like, \"Oh my gosh.\" And then you start looking at the trend of the referrals that are getting approved compared to the ones that were not getting approved, and you're like, \"Wow.\"\nQ: “It sounds like the entire compensation scheme was designed to promote off-label prescribing.”\nA: “I don't know if that would be a scheme, but there was really nothing there to stop it. I mean, whenever I was with [company name redacted], they were just black-and-white things that kept the communications with the sales reps on the commercial team; it was black and white. We just didn't do it. You would never provide—that information would never be provided, or it couldn't be provided, and it shouldn't even be asked. But not at Harmony. And the sales directors, they get paid on those just like the sales reps, no matter what it is...I think that there was pressure from management to deliver...the pressure is there.” -Ex-field reimbursement manager working with Harmony",
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      "text": "“there was really nothing to stop it...there was pressure from management to deliver...the pressure is there.” — Ex-field reimbursement manager working with Harmony",
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      "text": "Source: Scorpion Capital consultation calls with experts",
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      "text": "He described the “wow” moment when he and others figured out how reps were pushing off-label prescriptions: “there was really nothing to stop it...there was pressure from management to deliver...the pressure is there.” He painted reimbursement staff as fighting a losing battle in the face of aggressive sales managers who didn’t want to hear that “that’s not an indication supported for this drug” – “Can you possibly stretch? Can you possibly make excessive sleepiness narcolepsy? Can you possibly make it cataplexy? Can you possibly do that?”",
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