Corporate Compliance

Tip: Address anti-kickback and self-referral concerns

Healthcare Auditing Weekly, April 28, 2009

The hospital should have policies and procedures in place to deal with federal and state 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, including and applicable exception if the Stark Act is implicated
  • The hospital does not enter into financial arrangements that are designed to provide inappropriate remuneration to the hospital in return for a physician providing services to federal healthcare program beneficiaries at the hospital
  • 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 was adapted from The Compliance Officer’s Handbook, Second Edition. For more information about the book or to order your copy, visit the HCMarketplace.

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