Fourth Circuit Underscores the Risk of Commission-Based Compensation Agreements with Independent Contractors

In a recent decision, the Fourth Circuit Court of Appeals for the second time in two years held that commission-based compensation arrangements with independent contractors cannot be safe harbored and do violate the Anti-Kickback Statute and FCA.

🔒 Members Only · Compliance & Enforcement BriefYou’ve reached the member portion of this brief.Members read the full analysis and the source documents in every Brief, six days a week.