tci Medicare Compliance & Reimbursement - 2016 Issue 16

Compliance: Get a Handle On the Basics of On-Call Arrangements

Tip: OIG suspicious of fraud in the guise of on-call coverage. If your facility has an on-call arrangement with a physician or group of physicians, heed what the HHS Office of Inspector General’s (OIG’s) has to say about such an arrangement and the compensation associated with it. The twist in the tale lies in whether such arrangements take theStark Law and the Anti-Kickback Statute (AKS) into consideration when structuring the agreement and whether they follow the Fair Market Value (FMV) rates. Background: With a plethora of OIGAdvisory Opinions on the subject, an abundance of advice exists to...

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