decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Physician Practice Model Compliance Plan / Specific Risk Areas / Additional Risk Areas / Professional Courtesy
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Article Overview
This article explains the general compliance considerations surrounding professional courtesy arrangements in physician practices. It is aimed at physicians, practice administrators, compliance staff, and legal or billing professionals who need to understand the broad fraud-and-abuse issues that can arise when fees, copayments, or other out-of-pocket amounts are waived. The discussion centers on the types of arrangements described by the Office of Inspector General and the federal authorities that may be relevant depending on how recipients are selected and how the courtesy is extended.
Why This Topic Matters
Professional courtesy policies can create compliance risk if they interact with referral relationships, beneficiary cost-sharing, or federal program billing. Understanding the scope of those concerns helps practices evaluate whether their policies warrant legal or compliance review.
What You Will Learn
- How professional courtesy is generally described in physician practice settings.
- Which broad fraud-and-abuse concerns may be relevant to courtesy arrangements.
- Why the selection of recipients and the form of the courtesy both matter to compliance review.
- Why practices may seek legal review of uncertain courtesy policies.
Who Should Read This
- Physicians
- Physician practice administrators
- Compliance officers
- Medical billing staff
- Health care attorneys
Codes Discussed
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