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Mar 30, 2017 3:00:00 PM

How Do Recent Settlements Give Insight into Effective FMV and CR Compliance Programs?

As discussed frequently in compliance and health care conferences and forums and on this page, fair market value (FMV) of payments to referring physicians is an essential compliance requirement of the Stark law and federal anti-kickback statute. Physician compensation in excess of FMV is at the crux of much health care enforcement activity. As noted by Richard Kusserow, former Inspector General, “Arrangements with physicians are the highest compliance risk area in 2017” (“Kickback Cases Remain Top DOJ and OIG Priority in 2017,” Strategic Management Services, LLC; Jan. 2017). Mr. Kusserow further explained that whistleblowers are a significant source of enforcement activity.

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Topics: FMV, Compliance, CR

Feb 23, 2017 10:00:00 AM

3 Steps to Reduce Fraud and Abuse Compliance Risks in Hospital-Physician Deals

The most astute executives in health systems are rightfully concerned about compliance risks in physician contracting. Among these risks are that a transaction or an arrangement between a hospital and a physician are consistent with fair market value (FMV) and are commercially reasonable (CR) as those terms are defined in the healthcare regulatory context.

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Topics: Physician Compensation, FMV, Compliance, CR