tci Medicare Compliance & Reimbursement - 2003 Issue 15

Business Arrangements: PER-PATIENT FEE STRUCTURES RAISE COMPLIANCE RED FLAGS

If you're about to ink a business deal with another health care provider that involves a "per patient" payment structure, you could be running serious risks under the anti-kickback statute. The HHS Office of Inspector General made that point once again in an advisory opinion released April 10 (No. 03-8). In the opinion, the OIG takes the measure of one company's proposal to develop and manage distinct part rehabilitation units located within acute care hospitals. The company's management fee would be based on a per patient, per day basis. That sounded quick alarm bells with the watchdog agency. "'Per...

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