Best execution

Best execution obligations in Healthcare & Life Sciences sit at an underappreciated intersection: procurement and contracting practices for high-value medical goods and services are drawing scrutiny from the U.S. Centers for Medicare & Medicaid Services, the U.S. Department of Health and Human Services Office of Inspector General, and the European Medicines Agency, each applying distinct standards for how organizations must document that purchasing and distribution decisions serve patient and payer interests. The OIG's existing safe harbor regulations under the Anti-Kickback Statute create de facto best execution requirements for vendor selection, and CMS value-based care arrangements add a second layer of price-and-quality justification obligations. Compliance teams that have not mapped their GPO and specialty distributor contracts against both frameworks before the next audit cycle are carrying documented exposure.