Does Every Physician Position at Your Organization Have a Contract?

Posted on
March 22, 2016

Organizations must document all contractual arrangements with physicians, with payment terms set in advance that are unrelated to volume of services.

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Organizations must document all contractual arrangements with physicians, with payment terms set in advance that are unrelated to volume of services. This includes both compensated and uncompensated services. Work with administrators and chiefs of staff to ensure all contracted positions have signed agreements that include payment rates, defined services and time requirements, the expiration date, and a method for regular monitoring. Remember: even though the Stark Final Rule doesn’t mandate having a contract, you must have a signed arrangement in place, and it is still a best practice to have a formal contract.

Although call coverage agreements are expensive and often command the most attention, the OIG’s 2015 settlements and Fraud Alert demonstrate that special attention should be given to medical director, leadership and other administrative services arrangements. If your organization is not documenting both commercial reasonableness and fair market value for administrative positions, you may be putting the organization at risk. Ensure that you have policies in place for determining FMV for all arrangements and for archiving the necessary documentation.

If you want to read more key physician contracting compliance tips, check out this article.

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