Hospitals and Physician Relationships – Navigating Stark, AKS and Fraud Risks (Part III of III)
Chief compliance officers at hospitals face a crushing burden of risks. The HHS-OIG has vigorously scrutinized hospitals compensation of physicians, especially for potential anti-kickback and Stark law violations. Most of these suspect situations involve compensation for physician practice groups. Unlawful compensation and influence arrangements have involved favorable leasing and facility payments, such as below-market office leasing arrangements in exchange for exclusive referral of patients to...