Extract to table

Accordingly, any compensation arrangement that involves the sale or promotion of Pulsar™ devices — including the sales compensation plan under review — must be evaluated for AKS compliance

The individual receiving compensation must be a bona fide employee of the entity making the payment, as established by the common-law test of employment under the Internal Revenue Code (i

The employee must be engaged in employment that involves the furnishing of items or services for which payment may be made under a federal healthcare program

Two important limitations on the scope of the safe harbor must be noted: First, the employee safe harbor does not apply to independent contractor sales representatives

Solstice must ensure that no territory managers or other sales personnel are classified as 1099 independent contractors