Outpatient Surgery Magazine

OR Excellence Awards 2015 - September 2015 - Subscribe to Outpatient Surgery Magazine

Outpatient Surgery Magazine, providing current information on Surgical Services, Surgical Facility Administration, Outpatient Surgery News and Trends, OR Excellence and more.

Issue link: http://magazine.outpatientsurgery.net/i/568943

Contents of this Issue

Navigation

Page 46 of 168

4 7 S E P T E M B E R 2 0 1 5 | O U T P AT I E N T S U R G E R Y M A G A Z I N E O N L I N E to the practice or center. While an ideal exclusive arrangement with a lab would require the lab to participate in all payer programs with which the practice or center participates, this is not always practical or possible. At a mini- mum, there should be an understanding between the 2 parties that the lab will make some effort to seek payment for the services it renders to all the patients of the practice or center. The OIG's advisory opinion also cautions providers to be mindful of the fees actually charged to private insurance patients, in order to avoid a situation in which the fees charged to Medicare and Medicaid patients are "substantially in excess" of those charged to third-party payers. While "substantially in excess" charges against practices and centers are rare, the penalties for overcharging feder- ally funded programs in comparison to the facility's usual and cus- tomary charges are severe. Gastro practices and endo centers should always exercise caution in awarding exclusive contracts to secondary providers such as lab service companies. Before entering into any such exclusive agree- ment, physicians and facility administrators should consult with their legal counsel or an attorney who is experienced in healthcare and business laws and regulations. OSM Mr. Fanburg (jfanburg@bracheichler.com) chairs the health law practice at Brach Eichler in Roseland, N.J.

Articles in this issue

Links on this page

Archives of this issue

view archives of Outpatient Surgery Magazine - OR Excellence Awards 2015 - September 2015 - Subscribe to Outpatient Surgery Magazine