Fact Based List:
Becker's Hospital Review: 13 Key Questions for Hospital-Physician Relationships — Assessing Legal Compliance
Submitted by Anonymous on Tue, 05/24/2011 - 10:29
- Is the relationship truly needed?
- Is the position and payment wholly unrelated to referrals or the intent to retain business?
- How comparable is the position to other positions in the hospital when it comes to specialties of lower financial value?
- How comparable is the position to those at competing hospitals?
- Is the payment fair market value? If so, what evidence supports this? Is there a third party valuation or objective, external evidence to defend this value?
- Has the relationship between the hospital and the physician been approved by internal parties who are unrelated to the outside parties involved?
- Does the relationship meet a Stark Act exception & an anti-kickback safe harbor? If a nonemployment arrangement, is the relationship set to pay a fixed aggregate amount per yr & not vary per the yr ?
- Can a rebuttable presumption under the Internal Revenue Code be obtained that the relationship doesn’t create private inurement or excess benefit?
- Has the hospital’s compliance officer, or legal counsel, approved the relationship?
- Is there a contracting file with legal and valuation approval? Has there been a comprehensive and detailed review of legal concerns?
- Will the relationship be viewed in the context of an organization that has a culture of compliance?
- Is there a short memo that supports the true need for the relationship?
- Can this relationship be considered standard for the system, or is it highly creative and unusual?
Source: Becker's Hospital Review, May 24, 2011
Source URL: http://www.beckershospitalreview.com/hospital-physician-rela...
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