Tip: Auditing procedures pertaining to anti-kickback and Stark
Healthcare Auditing Weekly, April 11, 2007
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, according to the OIG Compliance Program Guidance for Hospitals. Such policies should provide that the following are true:
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All of the hospital's contracts and arrangements with referral sources comply with applicable statutes and regulations
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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 providing services to federal healthcare program beneficiaries at 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.
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