Compliance / Improper inducements, kickbacks and self-referrals

Why This Topic Matters

Improper referral incentives and conflicted financial relationships can expose practices to fraud-and-abuse liability, disrupt clinical decision-making, and create compliance risk for organizations that bill federal health care programs. The article helps readers recognize the broad categories of arrangements and policies that deserve review.

Article Sections

1. Compliance and fraud-and-abuse framework

   Introduces the compliance context for physician practice standards and the federal laws implicated by improper inducements and self-referral concerns.

2. General risk areas for physician arrangements

   Summarizes broad categories of outside business relationships and financial arrangements that may raise compliance concerns for a medical practice.

3. Cost-sharing and patient inducement concerns

   Covers policies related to routine waivers and other patient-facing inducement issues addressed in OIG guidance.

4. Practice standards for contracts, leases, and gifts

   Outlines additional categories of practice policies that may be included in a compliance program, including contracting and gift-related standards.