By Gina L. Campanella, Esq., FACHE

Due in no small part to the tireless efforts of our New Jersey state medical society lobbyists, several modifications to the Limitations on and Obligations Associated with Prescriber Acceptance of Compensation from Pharmaceutical Manufacturers (the “Pharma Regs”) have been published in the August 6, 2018 New Jersey Register. The official comment period on the proposal as published closes at the end-of-business on October 4, 2018, after which date it is anticipated that these revisions will be implemented as expeditiously as possible.

The critical changes include:

There will no longer be any limitation on cost of meals at any event that is an educational event, whether or not CME is awarded.
For non-educational meals, lunches are still limited to $15 per person but dinners have been raised to $30 per person. The dollar limits now also explicitly exclude delivery fees and can potentially be increased based upon the CPI without need for additional government action.
Thus far, no other aspect of the Pharma Regs have been modified and these changes are not yet officially active; however, the Attorney General’s office has advised that the old rules will not be enforced so long as the new proposed rules are being followed. Educational events where meals will be provided utilizing sponsorship from pharmaceutical companies can now be planned without need to wait for official adoption of the proposed revisions.