E/M Coding Alert - 2007 Issue 26
COMPLIANCE: 'Professional Courtesy' Could Cost Your Practice Tens Of Thousands
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Article Overview
This article explains how professional courtesy policies can create compliance exposure for medical practices when they intersect with federal health care programs, physician relationships, and billing practices. It is aimed at physicians, practice managers, compliance staff, and coding/billing professionals who need a high-level understanding of the legal and regulatory issues discussed, including Stark law, HHS Office of Inspector General guidance, and related state-law considerations. The article focuses on why these arrangements may be scrutinized and what broad categories of regulatory guidance affect them.
Why This Topic Matters
Professional courtesy policies can trigger legal and reimbursement risk if they are applied in ways that conflict with federal program rules, anti-fraud concerns, or physician referral relationships. Practices need to recognize the compliance implications before adopting or continuing such arrangements.
What You Will Learn
- The compliance concerns associated with professional courtesy arrangements in physician practices.
- How federal health care program participation can affect courtesy policies.
- Why federal self-referral and anti-fraud guidance may be relevant to these arrangements.
- Why state law considerations may also matter.
Who Should Read This
- Physicians
- Medical practice managers
- Compliance officers
- Billing and coding professionals
- Healthcare attorneys
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