Research conducted since 2015 shows that more companies are tracking aggregate spend on individual HCPs than in 2015. However, most teams still do not enforce an annual cap on compensation amounts. Among those that do, the majority have separate caps by activity. In particular, specific caps for speaking engagements, which have been closely scrutinized by regulators in the past, are very common.

Increasingly, regulators appear to be placing scrutiny on aggregate spend by companies as a potential anti-kickback violation. This is being fueled by reporting requirements that effectively place a lot of data in the public domain and allow regulators to quickly identify anomalous compensation amounts.

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