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Sources: 42 C.F.R. §  1001.952(a)(2) and 42 C.F.R. § 1001.952(a)(3)

4. Group Purchasing Organizations (GPO)

Statutory exception, plus a regulatory safe harbor if both of the following standards are met:

  1. written agreement with GPO fees fixed or capped at 3%; and

  2. GPO must disclose in writing at least annually the amount received from each vendor.

Anti-Kickback Safe Harbor
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