decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Medical Specialties / Phlebotomy / Special Fraud Alert, Oct 1994 - Provision of Phlebotomy Services to Physicians
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Article Overview
This article explains an OIG Special Fraud Alert addressing the provision of phlebotomy services to physicians and related health care entities. It focuses on the compliance and fraud-risk considerations that can arise when laboratory personnel are placed in office-based and other clinical settings, and why the issue matters to physicians, laboratories, and facility administrators. The discussion is relevant to readers seeking a broad understanding of anti-kickback exposure in routine specimen-collection arrangements without revealing detailed compliance analysis.
Why This Topic Matters
It helps practices, laboratories, and compliance teams understand a common operational arrangement that can create fraud-and-abuse risk in healthcare.
Article Sections
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Special Fraud Alert
Introduces the OIG fraud-alert topic and the general compliance concerns surrounding phlebotomy services in physician and other healthcare settings.
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Placement of phlebotomists in physician offices and other settings
Discusses the overall arrangement of laboratory staff working in non-laboratory environments and the types of operational issues the alert addresses.
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Contract and monitoring considerations
Addresses the role of agreements, supervision, and enforcement in evaluating the arrangement under fraud-and-abuse concerns.
What You Will Learn
- The general compliance issues associated with laboratory phlebotomy services in physician offices.
- Why placement of staff in clinical settings can be relevant to fraud-and-abuse review.
- How contracts and monitoring practices relate to the article’s compliance discussion.
- What types of healthcare settings are discussed in connection with the alert.
Who Should Read This
- Physicians
- Laboratory administrators
- Compliance officers
- Healthcare attorneys
- Revenue cycle and billing staff
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