KEY POINTS
Two Ministerial Orders that define the thresholds (i) for authorization or declaration of agreements with HCPs or HCOs covering permitted benefits, and (ii) for benefits to be considered of negligible value, were published on August 14th 2020.
Pursuant to the Decree of June 15th 2020, benefits that fall above or belowthresholds now defined in the first Ministerial Order will require either a declarationor an authorization by e-procedure to the relevant professional order or competent authority.
While declarations must be filed at the latest 8 days before the benefit is granted, the process for authorization could now take up to 4 months.
In addition, the second Ministerial Order defines the amount of authorized in-kind or cash benefits which are considered of “Negligible value”.
The abovementioned Decree and Ministerial Orders will enter into force on October 1st, 2020.
To get ready, anticipate these changes by:
- reviewing template agreements, policies and processes
- developing internal communication and training