tci Medicare Compliance & Reimbursement - 2005 Issue 1
LABS: Could Dialysis Arrangements Put Labs At Risk?
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Article Overview
This article discusses an HHS Office of Inspector General advisory opinion involving laboratory support arrangements with dialysis facilities. It is aimed at laboratory administrators, compliance staff, and revenue cycle professionals who need to understand broad fraud-and-abuse concerns, including anti-kickback risk, referral issues, and the compliance implications of providing services or supplies without charge. The article focuses on the general policy and compliance context surrounding dialysis-related specimen handling and laboratory relationships.
Why This Topic Matters
Laboratory and dialysis relationships can create fraud-and-abuse exposure if operational support is structured in a way that may influence referral patterns or reimbursement arrangements. Understanding the compliance concerns highlighted here helps organizations evaluate business practices before they create legal risk.
Article Sections
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HHS OIG advisory opinion context
Introduces the advisory opinion and frames the compliance issue involving laboratory support for dialysis facilities.
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Arrangement involving specimen preparation support
Describes the type of operational assistance being considered and the general setting in which it occurs.
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Compliance concerns and risk discussion
Summarizes the fraud-and-abuse concerns raised by the opinion and the broader implications for laboratory contracting and referrals.
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Lesson learned
Provides a brief takeaway about the need for caution when structuring relationships with dialysis facilities.
What You Will Learn
- The compliance issues that can arise in laboratory relationships with dialysis facilities
- How HHS OIG advisory opinions are used to evaluate fraud-and-abuse risk
- The general considerations surrounding referrals, discounts, and service arrangements
- Why operational support provided at no cost can raise regulatory concerns
Who Should Read This
- Laboratory administrators
- Compliance officers
- Revenue cycle professionals
- Healthcare counsel
- Dialysis facility managers
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