With the advent of health reform and ongoing consolidation in the health care industry, individual or small group providers are increasingly looking at ways to work together with others but maintain their current independent status. Often this is done through shared or managed office, facility or clinic arrangements. In addition to providers, sometimes these arrangements are established or promoted through lay persons.
The concern with these arrangements is that they are often established without carefully addressing regulatory constraints, especially federal and state self-referral and antikickback laws. Problem areas include: extent of layperson control over medical practice matters, manager compensation, joint operation of ancillary equipment and services, control over billing and collections, facility leasing and allocation of overhead. Since shared or managed arrangements are typically not fully integrated arrangements, it is more difficult to find exceptions or safe harbors that avoid regulatory problems. As a result, providers need to be aware of the pitfalls before moving forward with a shared or managed office arrangement.
This session by speaker Wayne Miller will discuss the following items:
Who should attend: Billers, coders, practice managers, physicians, medical groups, and health care facilities.
Wayne J. Miller, Esq., is a founding partner of the Compliance Law Group, Los Angeles, a law firm focused on health care industry legal compliance for clients nationwide. Wayne has practiced healthcare business and regulatory law throughout his 30-year career. His firm represents a wide range of healthcare industry clients throughout the nation. He is a frequent speaker for The Coding Institute national teleconferences on healthcare reimbursement, transactional and regulatory...
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