Outpatient Surgery Magazine

Would You Operate On This Patient? - October 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://outpatientsurgery.uberflip.com/i/584946

Contents of this Issue

Navigation

Page 32 of 196

3 3 O C T O B E R 2 0 1 5 | O U T P A T I E N TS U R G E R Y. N E T for bona fide services the physicians actually provide," reads the alert, which was issued in June. So if it's been a while since you examined how you're paying your medical director, now might be a good time to do so to make sure the arrangement is above board. Questionable quid pro quo The alert was triggered by the OIG's recent settlements with 12 physi- cians who had entered into "questionable medical directorship and office staff arrangements." The OIG alleged the arrangements repre- sented improper remuneration under the federal Anti-Kickback Statute because: • the payments to the physicians took the volume or value of patient referrals into account and did not reflect fair market value for the services to be performed, and • the physicians did not provide the services required under the arrangements. The OIG further alleged that, in some of the arrangements, the healthcare facility or system with which the physicians were affiliated paid their office staffs' salaries, which was seen as a violation as it "relieved the physicians of a financial burden they otherwise would have incurred." While the OIG determined that "the physicians were an integral part of the scheme and subject to liability under the Civil Monetary Penalties Law," its future investigations and sanctions are likely to hold facilities that hire medical directors or enter into other compen- sation arrangements with physicians liable if warranted. Drawing the line In light of the recent alert, surgical facilities and their member physi- cians are strongly advised to review all existing and future medical

Articles in this issue

Archives of this issue

view archives of Outpatient Surgery Magazine - Would You Operate On This Patient? - October 2015 - Subscribe to Outpatient Surgery Magazine