decisionhealth Newsletters, Answer Books - 2009 Issue 2 (February)
Fraud and Abuse / Improper inducements, kickbacks and self-referrals
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Article Overview
This article reviews physician practice standards for avoiding improper inducements, kickbacks, and self-referrals. It focuses on compliance themes such as federal fraud-and-abuse laws, fair market value arrangements, cost-sharing waivers, safe harbors, and other business relationships that can create risk for physician practices and their business partners. The content is intended for physicians, practice managers, compliance staff, and others responsible for structuring referral-related arrangements.
Why This Topic Matters
Improper referral-related arrangements can create legal and compliance exposure for physician practices and the organizations they work with. Understanding the general fraud-and-abuse framework helps practices identify risk areas and recognize when further review is needed.
Article Sections
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Compliance framework for physician practices
Introduces the federal fraud-and-abuse framework discussed in the article and the general compliance expectations for physician practices.
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Referral-related financial arrangements
Addresses business relationships with outside entities that may create concern when referrals or ordering patterns are involved.
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Cost-sharing waivers and patient inducements
Discusses patient-facing inducement concerns, including cost-sharing practices and the general compliance issues they can raise.
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Risk areas for practice policies and procedures
Summarizes categories of arrangements and interactions that practices may need to address in internal standards and procedures.
What You Will Learn
- The major fraud-and-abuse topics raised by physician referral relationships
- Why fair market value and compliance review are emphasized in practice arrangements
- Which types of practice relationships are commonly treated as risk areas
- How internal standards and procedures can be organized around referral-related concerns
Who Should Read This
- Physicians
- Medical practice managers
- Compliance officers
- Healthcare administrators
- Billing and coding professionals
Codes Discussed
Code Ranges Discussed
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