Patient Referrals

News & Analysis as of

The Halifax $85 Million Lesson: Compensation Arrangements Between Hospitals and Physicians Must Be Reviewed

The Department of Justice (“DOJ”) announced another multi-million dollar settlement of alleged False Claims Act violations on March 11, 2014. Specifically, Halifax Hospital Medical Center and Halifax Staffing, Inc. agreed to...more

Health Law Insights Newsletter - April 2014

In This Issue: - Federal Updates - State Updates - HIPAA Updates - Excerpt from Centers for Medicare & Medicaid Services Issues Guidance for Meaningful Use Hardship Exception: The Centers...more

Healthcare IT News: OIG Does An About-Face On Referral Service Pricing

The Department of Health and Human Services Office of Inspector General (OIG) recently terminated a favorable 2011 advisory opinion regarding a healthcare IT company's "per-click" pricing model for its provider referral...more

OIG Approves Referral Relationship Between Placement Agency And Retirement Community Operator Under Anti-Kickback Statute

On January 13, 2014, HHS’s Office of the Inspector General (“OIG”) issued an advisory opinion holding that the contractual relationship between an operator of retirement communities (the “Operator”) and an unrelated placement...more

New Law Changes Permissible Referrals for Physical Therapy

On January 1, 2014, AB 1000 went into effect. It is a combination of two bills: (1) AB 1000 for direct consumer access to physical therapy, and (2) AB 1003, sponsored by the California Medical Association, to permit...more

Exclusive Contracts Raise Anti-Kickback Issues

A new OIG Advisory Opinion 13-15, the OIG has resurrected the issue of whether awarding exclusive contracts to hospital based providers involves remuneration in exchange for referrals, because it grants the opportunity for...more

Bonuses for Physician Employees: Lessons Learned from the Halifax Hospital Case

This week, a federal district court in Florida concluded that a hospital violated Stark as a matter of law by entering into employment agreements with physicians that included bonus compensation that was not based exclusively...more

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