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. Health systems under investigation or under consent decrees report that an OIG investigation looks for consistent review processes, regular monitoring, internal audits and defined compliance guidelines. How confident are you that your physician contracts are 100% compliant with documentation of FMV on file?
We urge our subscribers to perform annual physician contract audits in addition to using consistent guidelines and documentation procedures throughout the year. Take advantage of a new month and plan a physician contract audit.
Links to Excellent 2015 Articles on These Topics:
- New Board Compliance Guidance Prompts General Counsel Focus, McDermott Will & Emery
- Tuomey’s Appeal of $237M False Claims Act Judgment Denied by the Fourth Circuit, McDermott Will & Emery
- Huge Hospital Settlements and Physician Culpability, McDermott Will & Emery
- Recent OIG Fraud Alert Put Physician Medical Director Agreements in Focus, Paul Hastings
- Physician Compensation Arrangements on OIG Radar, Nixon Peabody
- Recent DOJ and OIG Actions Show Growing Federal Scrutiny of Physician Financial Arrangements, McDermott Will & Emery
- Fraud Alert: Physician Compensation Arrangements May Result in Significant Liability, Office of the Inspector General, Department of Health and Human Services