Corporate Compliance

Tip: Recruitment arrangements

Compliance Monitor, August 27, 2008

Incentives can help bring needed physicians to an underserved community, but recruitment arrangements pose substantial fraud and abuse risks.
 
Be especially careful when a recruited physician establishes a private practice instead of becoming a hospital employee. The arrangements may implicate the Anti-kickback Statute if one purpose of the arrangement is to induce referrals.
 
Safe harbor protection is available for certain recruiting arrangements used to attract primary care physicians, but the scope of the safe harbor is very limited.
 
The OIG recommends examining these four areas of recruiting arrangements:
  • The size and value of the recruitment benefit
  • The duration of the payout of the recruitment benefit
  • The practice of the existing physician
  • The need for the recruitment
This tip was adapted from the Compliance Program Effectiveness Handbook. For more information about the book or to order your copy, click here. For even more information on recruitment arrangements, join HCPro on September 10, at 1 p.m. (Eastern) for the live audioconference Stark Law Update: Physician Recruitment in the Post-Stark II Phase III World.

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