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When your organization determines it must compensate a physician above your standard for fair market value, create a standardized process for reviewing such exceptional contracts.
Whatever method, document the rationale and approval process and stick to a consistent method.
Organizations must document all contractual arrangements with physicians, with payment terms set in advance that are unrelated to volume of services.
Board oversight of physician contracts is an important component of a strong compliance program.
The OIG actions of the past two years illustrate the risks of noncompliant contracts to healthcare organizations and individuals who do not have a comprehensive compliance program for review and documentation of physician contracts.
When our subscribers ask about physician contract compliance best practices, we caution them to be sure that the annual payment, the hourly rate, and the hours of service are compliant, and that contract performance and payments are tracked.
Payment and hours of service benchmarks for medical directorships are available from several sources.
Payment and hours of service benchmarks for medical directorships are available from several sources.
Establishing a fair and compliant payment rate for a position that does not need a particular type of specialist can be a challenge!
Recent actions by the OIG make it clear that they are investigating physicians as well as hospitals when they suspect a physician contract violates Stark, Anti-Kickback, or False Claims Act regulations.
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