decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Anti-Kickback Advisory Opinion Summaries / 2005 OIG Advisory Opinions / Opinion 05-05 - Cardiologists May Enter Gainsharing Arrangement With Hospital
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Article Overview
This summary article reviews an Office of Inspector General advisory opinion involving a hospital and a group of cardiologists. It discusses the general compliance concerns raised under federal fraud-and-abuse rules, the broad categories of safeguards described in the opinion, and why the arrangement was considered in relation to both civil monetary penalty and Anti-Kickback Statute risks. It is most relevant to healthcare compliance professionals, hospital administrators, physicians, and coding/reimbursement teams who monitor physician-hospital financial relationships.
Why This Topic Matters
Advisory opinions like this help healthcare organizations understand how physician incentive arrangements are evaluated under federal fraud-and-abuse law and what types of safeguards are commonly reviewed.
Article Sections
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Summary of the Advisory Opinion
Introduces the hospital-physician arrangement reviewed by OIG and the overall compliance issues considered in the opinion.
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Civil Monetary Penalty Considerations
Describes the civil monetary penalty concerns discussed in the opinion and the broad categories of safeguards noted by the agency.
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Anti-Kickback Statute Considerations
Summarizes the Anti-Kickback Statute issues addressed in the opinion and the general factors that influenced the agency's analysis.
What You Will Learn
- How an OIG advisory opinion can address physician-hospital financial arrangements
- What broad fraud-and-abuse concerns arise in gainsharing discussions
- Which types of safeguards are commonly referenced in compliance reviews
- How federal oversight bodies evaluate risk in hospital incentive arrangements
Who Should Read This
- Healthcare compliance professionals
- Hospital administrators
- Physician practice managers
- Cardiology administrators
- Medical coding and reimbursement staff
- Healthcare attorneys
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