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O U T P A T 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 | O C T O B E R 2 0 1 5
Are You Paying Your Medical Director Fairly?
The feds are clamping down on physician compensation arrangements.
T
he federal government is clamping down on physician com-
pensation arrangements such as medical directorships, pay-
ing particular attention to whether surgical facilities are
compensating physicians for their past or future referrals of federal
healthcare program business. Basing pay on the number of referrals
may violate the Anti-Kickback Statute.
In a rare fraud alert, the Department of Health and Human Services'
Office of Inspector General urged surgical centers and other health-
care providers to scrutinize their medical director arrangements for
compliance with fraud and abuse laws and to report non-compliant
arrangements to federal authorities (osmag.net/sQQQn8). "Physicians
who enter into compensation arrangements such as medical director-
ships must ensure that those arrangements reflect fair market value
L E G A L U P D A T E
John D. Fanburg, JD, and Lani M. Dornfeld, JD
z OUT OF BOUNDS
The federal govern-
ment is cracking down
on medical director
arrangements that
reward referrals.