Office-based specialists, from ENT’s to urologists, often enter into suite sharing arrangements. No problem! That is, until they make it one.
Unfortunately they frequently create a partnership or partnership-like expense sharing arrangement that, to the outside world, appears to be an actual medical practice entity or, even worse, appears to government enforcement agencies and prosecutors to be a conspiracy.
Take, for instance, an arrangement in which a suite sharing “group” forms a partnership that doesn’t meet the Stark law definition of a group, but which, as a matter of everyday business, facilitates the submission of bills for, say, in-office imaging services performed by a partnership employee while the ordering physician, who supposedly personally supervised the employee’s performance, was at the hospital doing a procedure.
And yet the bill goes out, either under the supposed supervising physician’s name or under the name of the group referencing his name.
What was imagined to be a nice way to hold down expenses or even to project a united image to the outside world, has been transformed into fraudulent billing that can impact and infect each of the participants.
All you wanted to do was to share office space, not cell space.
Plan your arrangement carefully before you start engaging it.
