decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Fraud Alerts / OIG Special Fraud Alerts / Special Fraud Alert_February 2000 / Time and space considerations
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Article Overview
This article explains an OIG Special Fraud Alert focused on time-and-space considerations in rental arrangements. It is relevant to providers, suppliers, compliance teams, and healthcare administrators who structure or review office-space leases and shared-space payments. The article outlines broad areas of concern, including space usage, time usage, non-exclusive occupancy, and the allocation of charges among exclusive and common areas.
Why This Topic Matters
Improperly structured rental arrangements can create fraud and abuse risk, particularly when payments may be viewed as tied to referrals rather than legitimate space use. The article is useful for evaluating whether leasing and proration practices are documented, reasonable, and aligned with compliance expectations.
Article Sections
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Overview
Introduces the general fraud-and-abuse concern associated with rental arrangements for physician office and related space.
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Examples of suspect arrangements
Summarizes broad categories of arrangements the alert identifies as potentially problematic, including issues involving space use, time use, and occupancy patterns.
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Apportionment of exclusive office space
Discusses how rental allocations for dedicated office space are approached in relation to time and area used.
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Apportionment of interior office common space
Addresses shared interior areas in physician offices and how charges for those areas are divided among users.
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Apportionment of building common space
Covers shared building-level areas and the general approach to allocating associated charges among tenants and subtenants.
What You Will Learn
- The compliance concerns associated with office-space rental arrangements.
- How the article frames time and space as factors in rental evaluation.
- The broad categories of shared and exclusive space discussed in the alert.
- The type of documentation and review considerations emphasized by the OIG.
Who Should Read This
- Healthcare compliance professionals
- Physicians and physician groups
- Suppliers and ancillary service providers
- Practice administrators
- Healthcare attorneys and auditors
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