decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Hospital Model Compliance Plan / Risk areas / Gainsharing - Payments to reduce or limit services
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Article Overview
This premium article explains a hospital compliance risk area involving physician incentive arrangements that may be structured around reducing or limiting services. It is aimed at compliance staff, revenue integrity professionals, legal counsel, and healthcare administrators who need a high-level understanding of federal civil monetary penalty exposure, Anti-Kickback Statute concerns, and the role of OIG guidance and advisory opinions in evaluating these arrangements.
Why This Topic Matters
Hospitals and physicians can face significant regulatory exposure if incentive arrangements are viewed as improperly influencing care decisions or referral patterns. The article helps readers recognize the compliance issues involved and understand why federal guidance and advisory opinions are important when assessing these payment models.
What You Will Learn
- The general compliance risks associated with physician incentive arrangements in a hospital setting.
- How federal civil monetary penalty concerns and Anti-Kickback Statute concerns can arise in this context.
- Why hospitals may consider OIG guidance and advisory opinions when reviewing payment arrangements.
- Broad considerations for evaluating cost-savings arrangements under federal compliance standards.
Who Should Read This
- Hospital compliance officers
- Healthcare attorneys
- Revenue integrity professionals
- Physician practice administrators
- Healthcare executives
- Risk management teams
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