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  "presentationDate": "2023-03-28 00:00:00",
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      "kind": "callout",
      "text": "Compensation structure was allegedly designed to incentivize off-label fraud; regional managers and reps hounded reimbursement staff for information they could use to convert off-label scrips to on-label",
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      "text": "He highlighted the aberrant nature of the incentive plan – “this is the only situation I’m aware of in my tenure working in reimbursement” and wondered why the rep is getting paid “for patients that don’t get the drug...no one else is getting paid on that...the pharmacy is not getting paid.” Then he explained why: reps were incentivized to proliferate off-label prescriptions as they could then “go back in and salvage two or three of those patients that were off-label – but my question is, what happened to make from off-label to on-label?...I mean, did the patient suddenly get worse?”",
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      "text": "Q: “What’s your commentary on what you think is essentially fraudulent, because that’s basically what you’re describing. And, by the way, you’re not the only person to describe that to me.”\nA: “I would say whenever you’re compensating someone—this is the only situation that I’m aware of in my tenure working in reimbursement, working in contract management, working with Cigna’s and the Aetna’s and even working with the smaller Blues plans and the Medicaid plans...I’m trying to give kind of a global perspective on how one makes this assessment. I mean, you don’t get paid for patients that don’t get the drug. You just don’t. No one else is getting paid on that. The pharmacy is not getting paid.”\nQ: “So, why do they do that? Because they just think they’ll get a certain percentage of those through?”\nA: “I think that’s part of it. Part of the strategy might be that they can go back in and salvage. I mean, people go back in and salvage two or three of those patients that were off-label, hey—but my question is, what happened to make it from off-label to on-label? What happened? I mean, did the patient suddenly get worse?”\nQ: “What were you observing over and over that led you to think that this was happening? I mean, obviously, I think you’ve talked about it, but just to make sure that I understood properly.”\nA: “You know, why do you need to know that these were off-label? Why is that so important? Why do you need to know what the indication was that was originally given? I mean, it was off-label? I mean, maybe it was a hang-nail.” -Ex-field reimbursement manager working with Harmony",
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      "text": "I would say whenever you're compensating someone—this is the only situation that I'm aware of in my tenure working in reimbursement... I mean, you don't get paid for patients that don't get the drug. You just don't. No one else is getting paid on that. The pharmacy is not getting paid. — Ex-field reimbursement manager working with Harmony",
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      "text": "Source: Scorpion Capital consultation calls with experts",
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