In the rush to meet compliance requirements, the defect is focusing solely on the checklist of notions that are said to demonstrate compliance.
Tag: OIG
OIG Issues Fraud Alert on Physician Compensation
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…
New OIG Advisory Opinion 13-15 Sheds Further Light on Company Model Type Arrangements
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.