tci Medicare Compliance & Reimbursement - 2016 Issue 16
Compliance: Get a Handle On the Basics of On-Call Arrangements
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Article Overview
This article explains the compliance issues that can arise when hospitals or other facilities structure on-call coverage arrangements with physicians or physician groups. It focuses on general guidance around fair market value, commercially reasonable terms, compensation concerns, and the roles of the Stark Law, the Anti-Kickback Statute, and OIG advisory guidance. The piece is aimed at healthcare administrators, compliance professionals, and physicians who negotiate or review on-call agreements.
Why This Topic Matters
On-call arrangements can create legal and compliance risk if compensation is not structured carefully. Understanding the broad factors discussed in this article can help readers recognize when an agreement may need closer legal, compliance, or valuation review.
Article Sections
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Tip
A brief introduction to the compliance concerns that can arise in on-call coverage arrangements and the need to consider federal fraud-and-abuse guidance.
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Background
An overview of the general advisory context and the regulatory issues that commonly shape on-call compensation discussions.
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Quick reference
A short summary of the main compliance themes discussed in relation to physician coverage arrangements and valuation.
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Watch Out for These Problem Areas
A discussion of common compensation structures and contract features that may require closer review in on-call agreements.
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What is FMV?
A general explanation of how fair market value is considered in relation to on-call coverage and the types of factors that may affect it.
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Negotiations Inventory
A practical overview of broad contract considerations that may be reviewed when negotiating on-call arrangements.
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Take a second look
A concluding note encouraging final legal or compliance review before an agreement is signed.
What You Will Learn
- How compliance concerns can affect on-call coverage arrangements
- Why fair market value matters in physician compensation discussions
- What broad contract factors are commonly reviewed in on-call negotiations
- How federal fraud-and-abuse concepts relate to coverage agreements
- Why legal and compliance review may be important before finalizing an arrangement
Who Should Read This
- Physicians
- Hospital administrators
- Healthcare compliance professionals
- Medical group managers
- Healthcare attorneys
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