The U.S. Health and Human Services Office of Inspector General (OIG) released a Fraud Alert today titled Physician Compensation Arrangements May Result in Significant Liability. The OIG directs health care professionals (HCPs) to carefully evaluate compensation arrangements, including medical directorships and office staff arrangements, to confirm that (i) the compensation represents fair market value (FMV) for bona fide services; (ii) the FMV payment does not take into consideration the HCP’s past or future volume or value of referrals to Federal health care programs; and (iii) the services will actually be provided. The Fraud Alert directs HCPs to the OIG’s Compliance Program Guidance for Individual and Small Group Physician Practices and A Roadmap for New Physicians: Avoiding Medicare and Medicaid Fraud and Abuse for more information for additional information.

Posted by Cooley

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