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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

  • work Practice Area

    Health

Date & Time
  • event Date

    Wednesday, August 24, 2022

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$297.00
CLE
ALL

This CLE course will guide healthcare counsel on physician compensation arrangements. The panel will examine the legal requirements and the many potential risks. The panel will discuss the implications for Stark, Anti-Kickback, and False Claims Act (FCA) compliance, as well as offer best practices for structuring compensation arrangements.

Faculty

Anna M. Grizzle
Member
Bass Berry & Sims Plc

Ms. Grizzle focuses her practice on representing healthcare providers and companies in operational and compliance matters, investigations, and litigation. She works with clients to develop policies in anticipation of government and commercial payor claims audits and represents clients in responding to claims audits and in the appeals of audit results.

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Christina C. Street
Partner
Horne, LLP

Ms. Street specializes in physician contracting arrangements and business valuation. She has experience with several large hospital systems and group practices in the development and implementation of physician compensation modeling and fair market value contractual agreements.

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Description

Physician compensation arrangements are increasingly sophisticated and present liability risks. Recent enforcement actions involving compensation arrangements and guidance published by the Office of Inspector General (OIG) put physicians on notice that compensation arrangements must be for bona fide services and at fair market value (FMV).

Compensation arrangements must also comply with the Stark law and FCA, among others. Any attempt to compensate a physician for past or future referrals may violate the Anti-Kickback Statute (AKS) and expose the parties to penalties and sanctions, including exclusion from Medicare and other federal healthcare programs.

Similarly, risks for fraud in compensation arrangements are rife; key risk areas include reporting, accounting practices, descriptions of work performed, and more. Healthcare counsel must seek to minimize liability exposure while ensuring compliance when structuring physician compensation arrangements.

Listen as our authoritative panel of healthcare attorneys examines the legal requirements for physician compensation arrangements and addresses commercial reasonableness and FMV issues. The panel will also discuss lessons that can be learned from recent enforcement actions and will offer best practices for structuring and auditing physician compensation arrangements.

Outline

  1. Legal requirements for physician compensation arrangements
    • Stark Law
    • AKS
    • FCA
  2. Commercial reasonableness and FMV
    • Understanding regulatory definitions and application to operations
    • Compensation stacking
    • Physician losses
  3. Enforcement
  4. Best practices for structuring and auditing physician compensation arrangements

Benefits

The panel will review these and other key issues:

  • What steps can healthcare advisers take to ensure regulatory compliance when valuing physician compensation?
  • What are the implications for compliance with the Stark Law, the AKS, and other laws and regulations?
  • What lessons can healthcare counsel take away from recent enforcement actions?