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Wisconsin Health Law Posts
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- Medicare Opt-Out – A Make-or-Break Decision for Concierge Physicians
- Hybrid Concierge Models – Why Popularity Comes With Compliance Risk
- Cash-Based Clinics – A Regulatory Landscape More Complex Than It Appears
- State Spotlight: Wisconsin, Illinois, and Michigan — Three Distinct Regulatory Environments
- Understanding HIPAA and Its Interaction with State and Federal Confidentiality Laws
- Concierge Medicine Legal Guide: Key Compliance and Business Issues for Physicians
- Direct Primary Care (DPC) vs. Concierge Medicine: A Regulatory Comparison
- Physician Autonomy in the Value-Based Care Era: Legal and Operational Priorities for Health Care Providers
- Telehealth and Concierge Medicine – A Strong Fit with Complex Rules
- Preparing for Certification Surveys at Ambulatory Surgery Centers
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Tag Archives: anti-kickback statute
Concierge Medicine Article Series | The Anti-kickback Statute in Concierge and Cash-based Medical Practices
By John Fisher, JD, CHC, CCEP The Concierge and Cash-Based Medical Practice Article Series explores the evolving landscape of healthcare delivery models that prioritize patient-centered care, transparency, and direct financial relationships between patients and providers. Through this series, readers will … Continue reading
Posted in Consierge & Cash-Based Practices, Fraud and Abuse, Medicare and Medicaid, Physician Issues, Reimbursement & Payment Practices, Stark Law and Anti-Kickback Issues, Telemedicine, Uncategorized
Tagged anti-kickback statute, Concierge Clinics, Concierge Medicine, direct primary care, Telemedicine, wisconsin health lawyer
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THE OIG ADVISORY OPINION PATHWAY FOR CONIERGE AND CASH-BASED PRACTICES
For arrangements that are novel, involve significant financial investment, or present a unique structural profile without a clear safe harbor fit, the OIG Advisory Opinion process provides a mechanism for obtaining binding regulatory guidance. Under 42 C.F.R. § 1008.38, a … Continue reading
Posted in Consierge & Cash-Based Practices, Fraud and Abuse, Medicare and Medicaid, Physician Issues, Reimbursement & Payment Practices, Stark Law and Anti-Kickback Issues, Wisconsin Health Laws
Tagged anti-kickback statute, Cash-Based Medical Practices, Concierge Medicine, concierge practice, direct primary care, Medicare Reimbursement, wisconsin health lawyer
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SAFE HARBORS MOST RELEVANT TO CONCIERGE AND DPC PRACTICES
The regulatory safe harbors at 42 C.F.R. § 1001.952 provide the primary mechanism for structuring arrangements that would otherwise implicate the AKS. An arrangement that satisfies every element of an applicable safe harbor is protected from AKS prosecution. An arrangement … Continue reading
Posted in Compliance Issues, Consierge & Cash-Based Practices, Fraud and Abuse, Stark Law and Anti-Kickback Issues, Wisconsin Health Laws
Tagged anti-kickback statute, Cash-Based Medical Practices, Concierge Medicine, wisconsin health lawyer
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WHY CONCIERGE AND DPC PRACTICES ARE NOT AUTOMATICALLY EXEMPT
The AKS exposure of a concierge or cash-based practice depends heavily on its specific structure and business relationships. The analysis differs materially across three broad categories of practice. A. Pure Cash / DPC Practice — No Federal Program Participation A … Continue reading
Posted in Consierge & Cash-Based Practices, Fraud and Abuse, Medicare and Medicaid, Stark Law and Anti-Kickback Issues, Telemedicine, Wisconsin Health Laws
Tagged anti-kickback statute, Cash-Based Medical Practices, Concierge Medicine, Hybrid Concierge Practice, Medicare Opt-Out
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Investment Interest in Radiation Therapy Anti-kickback Statute Settlement
By Fisher, JD, CHC, CCEP Radiation Therapy Referral Kickback Arrangements with Investors Overview A national operator of radiation therapy centers agreed to resolve allegations that it caused the submission of false claims by entering into investment-related arrangements that allegedly violated … Continue reading
Posted in Compliance Issues, False Claims Act, Fraud and Abuse, Medicare and Medicaid, Physician Issues, Radiology Issues, Stark Law and Anti-Kickback Issues
Tagged anti-kickback statute, Investment Interest, Radiation Therapy
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Treatment Center Plead Guilty to Anti-kickback Statute Violations Involving Alcohol and Drug Addiction Treatment Centers
By Fisher, JD, CHC, CCEP Substance Abuse Treatment Center Owners Plead Guilty in Fraud Scheme The Department of Justice recently announced that two owners of a licensed alcohol and substance abuse treatment provider pleaded guilty for their roles in what … Continue reading
Posted in Compliance Issues, Fraud and Abuse, Medicare and Medicaid, Stark Law and Anti-Kickback Issues, Uncategorized
Tagged Alcohol and Drug Addiction, anti-kickback statute, Treatment Center
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Free Transportation Services to Patients and Guests – When Is The Anti-Kickback Statute Violated?
Free Transportation Services and the Anti-kickback Statute Advisory Opinions, Safe Harbors, and other Guidance It is a fairly common practice for healthcare facilities, whether long term care facilities, hospitals, or large clinics, to offer free transportation services to patients and … Continue reading
Posted in Compliance Issues, Fraud and Abuse
Tagged anti-kickback statute, free transportation, patient transportation, regulations, safe harbor
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