decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Joint Ventures / 'Carve Outs' Do Not Cut it for Suspicious Joint Ventures
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Article Overview
This premium article examines an Office of Inspector General advisory opinion about joint venture arrangements between a medical equipment supplier and physician practices. It explains the general compliance concerns raised by carve-outs from Medicare and Medicaid, the types of services and revenue-sharing structures involved, and why the arrangements drew scrutiny under fraud-and-abuse rules. The piece is relevant to compliance staff, healthcare attorneys, practice managers, and providers evaluating joint ventures or referral-related business arrangements.
Why This Topic Matters
It helps readers understand how non-federal carve-outs can still create regulatory risk when business arrangements may be viewed as indirectly rewarding referrals. The article is useful for evaluating joint venture structures before they are implemented.
What You Will Learn
- How an OIG advisory opinion can affect evaluation of joint venture arrangements
- Why excluding Medicare and Medicaid claims may not resolve compliance concerns
- What general features of a physician-supplier arrangement can raise fraud-and-abuse scrutiny
- How compliance professionals should think about indirect referral risk in private-pay business structures
Who Should Read This
- Healthcare compliance professionals
- Medical practice administrators
- Healthcare attorneys
- Physician group leadership
- Medical equipment suppliers
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