Tip: Address anti-kick back statutes and Stark Law
Healthcare Auditing Weekly, December 16, 2008
According to the OIG’s Supplemental Compliance Program Guidance for Hospitals, hospitals should have policies and procedures in place to address state and federal anti-kickback statutes, as well as the Stark physician self-referral law. Such policies should provide that the following are true:
- All of the hospital’s contracts and arrangements with referral sources comply with applicable statutes and regulations.
- The hospital does not enter into financial arrangements that are designed to provide inappropriate remuneration to the hospital in return for a hospital-based physician’s providing services to federal healthcare program beneficiaries a that hospital.
Make sure that policies and procedures address and define the OIG’s safe harbor regulations, which outline payment practices that would be immune from prosecution under the anti-kickback statute.
This tip is adapted from The Compliance Program Effectiveness Handbook. For more information about the book or to order your copy, visit HCMarketplace.
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