Even if you have no interest in neuromonitoring, the concepts discussed in the advisory opinion impact business schemes in other referral-based specialties, notably in regard to anesthesia in the ambulatory surgery setting.
Tag: inspector
You must be extremely careful when entering into any physician compensation arrangement, whether you are the payor or the recipient in order to steer clear of possible AKS violations.
All-Points Bulletin: Be on the lookout for the following suspect: No race. No sex. No height. No weight. Approximately zero to 6 years of age. Name unknown. Alias: Suspect Joint Venture. If seen, contact OIG or DOJ. Or, just blow the whistle and claim a bounty. As healthcare moves from the hospital setting to an […]
The federal Anti-Kickback Statute (the “AKS”) makes it a crime to pay remuneration to induce a referral of a federal health care program patient. Many are familiar with the safe harbors, the exceptions, for physician employment agreements and for personal services contracts. But many mistakenly believe that simply following the “recipe” set out in those safe […]
The OIG has released a new opinion (13-15) questioning the legality of a carve out provision in an anesthesia exclusive contract in favor of the referring medical group.
