decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Compensation and Remuneration / Additional guidance for compensation arrangements between hospitals and doctors
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Article Overview
This article reviews supplemental OIG compliance guidance for hospitals on compensation and remuneration arrangements with physicians. It explains the general compliance concerns hospitals should consider, the role of Anti-Kickback Statute Safe Harbors, and the types of internal questions OIG suggests using when evaluating whether an arrangement should proceed. It is aimed at compliance, billing, and legal or administrative staff who review physician contracting and hospital compensation practices.
Why This Topic Matters
Hospitals and physician-relationship teams need to recognize when compensation arrangements may raise fraud and abuse concerns and when additional review is warranted. The guidance helps readers understand the compliance framework and the kinds of documentation and operational safeguards that are relevant to these arrangements.
What You Will Learn
- The compliance issues OIG highlights in hospital-physician compensation arrangements
- How Safe Harbor analysis fits into compensation arrangement review
- What broad factors hospitals are encouraged to evaluate before proceeding with an arrangement
- Why documentation, fair market value review, and operational safeguards matter in these arrangements
Who Should Read This
- Hospital compliance officers
- Medical practice administrators
- Physician contracting teams
- Health care attorneys
- Billing and reimbursement professionals
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