Good Works FAQ

Q. What is Good Works Health?

A. Medical professionals who are invited to participate in online marketing programs with Good Works Health are given the opportunity to view educational marketing material, complete a survey and for the time they spend, direct a charitable contribution to a registered, legitimate charity of their choice. Good Works Health is the first and only OIG-approved marketing platform to deliver charitable contributions in the name of medical professionals for marketing purposes.A. Medical professionals who are invited to participate in online marketing programs with Good Works Health are given the opportunity to view educational marketing material, complete a survey and for the time they spend, direct a charitable contribution to a registered, legitimate charity of their choice. Good Works Health is the first and only OIG-approved marketing platform to deliver charitable contributions in the name of medical professionals for marketing purposes.

Q. How does it work?

A. A doctor is invited via email or by an invitation through a sales representative. A link directs them to an online promotional program and survey. The doctor reviews the presentation and responds to survey questions. Upon completing the survey, the doctor would be able to designate a charity to receive a monetary contribution.

Q. What kinds of charities are permitted?

A. Any 501(c)(3) of the Internal Revenue Code(“IRC”) that qualifies as a public charity under section 509(a) of the IRC and that meets the public support test under section 509(a) of the IRC.3. There are literally hundreds of thousands of charities that meet these criteria. However, contributions would not be allowable to private foundations. Good Works Health maintains an updated listing of these charities to enable doctors to select the charity of their choice.

Q. Are there any requirements for the doctor to meet?

A. The doctor must complete the survey and they must certify that neither they, nor any immediate family member holds a position on the board of the designated charity, is employed by the charity, or has any other financial relationship with the charity (including through their medical practice).

Q. What is the survey?

A. Physicians are required to complete an online survey related to educational needs, current product usage by indication, brand awareness and effectiveness, clinician attitudes, effectiveness of detailing programs, current best practices, and/or competitive product analysis. The survey maybe used by the clinical, scientific, and/or marketing divisions of drug and medical products companies. It can promote or market particular drugs. All information related to particular drugs or products must comply with approved product labeling.

Q. In what types of programs can Good Works Health be utilized?

A. It can be utilized for promotional programs and/or for research or educational purposes. It cannot be provided as part of any electronic prescribing transaction.

Q. Is there a tax benefit for doctors that provide charitable contributions through Good Works Health?

A. No. Charities that receive contributions through Good Works Health will see that the contribution was made “in the name of” the doctor, but it is not tax-deductible for the doctor.

Q. What are the OIG requirements for tracking the charitable contributions?

A. There is not a requirement for pharma to track. The OIG requires that contributions be tracked by Good Works Health by doctor and by contribution. The OIG letter states that the pharma company cannot know which doctors gave to which charities, but they can know which doctors participated and how much they contributed and when the contribution was made.

Q. What safeguards are in place for compliance?

A. All donations are made directly to charities. No funds are transmitted to healthcare professionals. Donations cannot be restricted or earmarked. Doctors must certify that neither they, nor a family member, holds a position on the board of the charity, is employed by the charity, or has other financial relationships. The charitable donations would not be determined in any manner that relates to a healthcare professional’s prescribing choices, thereby precluding any potential link between the opportunity and a healthcare referral. The pharma client would not be apprised of any individual healthcare professional’s charity of choice, minimizing any opportunity for clients to use that information to identify charities favored by a particular doctor. Moreover, the surveys and offer would not be provided as part of any electronic prescribing transaction, thus eliminating any explicit link between the opportunity and a prescription or order of a product. Information must be FDA compliant and must not be used for any off-label marketing. Finally, there are dollar limits on the donation per completed survey (which are uniform for all respondents of a given survey), and on the annual aggregate donation to anyone charity on behalf of any one doctor.

Q. Are there any caps on number of programs that a doctor can attend annually or per program?

A. No. There is a limit to how much a doctor can give to an individual charity during a calendar year, but not how many programs can be taken, and charitable contributions given during a year. Good Works Health tracks this to ensure that this limit is not exceeded. Once the limit is reached, a doctor can give to another charity.

Q. Are there any restrictions to the types of programs for which it can be utilized?

A. It can be utilized with any promotional campaign tactics (e.g., Impact Extender) and rep programs, as long as it meets the noted criteria.

Q. Are there any issues with the anti-kickback statute?

A. The OIG concluded that it would not constitute prohibited “remuneration…directly or indirectly…in cash or in kind” to the healthcare professionals within the meaning of the anti-kickback statute.