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Would all of your financial arrangements with physicians
pass regulatory scrutiny? The Centers for Medicare & Medicaid
Services (CMS) wants to know, and it wants to know soon. CMS
has made the review of financial arrangements between physicians
and hospitals a top focus area in an effort to determine whether
relationships are compliant with the physician self-referral
statute and other regulations.
Hospitals maintain financial arrangements with physicians
to serve a variety of purposes. Arrangements include contracts
for recruitment, call coverage, medical directorships, professional
services, management services, and property leases. A typical
hospital may have hundreds of these arrangements, and management
of them may occur in disparate areas of the hospital. By auditing
all physician contracts and all payments to physicians, you
will be able to ensure that your physician arrangements are
compliant with the Anti-Kickback Statute, Stark law, and tax
exemption-related laws. You will then be positioned to implement
policies and procedures that enable centralized management
and control of physician arrangements.
Specific learning objectives include:
Gain a better understanding of the laws and regulations
impacting
hospital/physician arrangements.
Learn a proven approach to audit your financial relationships
and
determine corrective actions.
Understand how to develop and implement a corrective
action plan.
Learn how to establish processes and controls for new
and updated
physician arrangements.
The featured presenters for this session are:
Ms.
Shannon Dwyer, Senior Vice President & General Counsel,
St. Joseph Health System
Ms. Dwyer brings over 17 years of Catholic healthcare experience
to her role as General Counsel for St. Joseph Health System
(SJHS). SJHS is an integrated healthcare delivery organization
that exists to extend the healing ministry of Jesus in the
tradition of the Sisters of St. Joseph of Orange. SJHS provides
a broad range of medical services within three geographic
regions: Northern California, Southern California, and Western
Texas/Eastern New Mexico. With total revenues of $3.9 billion,
the system is enriched by the services of more than 24,000
employees and includes 14 hospitals and 3 home health agencies,
as well as hospice care, outpatient services, skilled nursing
facilities, and physician organizations. As General Counsel,
Ms. Dwyer provides leadership to the Legal Department, as
well as counsel to SJHS, its ministries, the Board of Trustees,
and executive management on a broad range of matters, including
transactions, corporate governance, complex contracts, medical
staff peer review, licensing and accreditation, and state
and federal regulatory compliance. Ms. Dwyer is a member
of The State Bar of California, the American Health Lawyers
Association, the Health Law Section of the American Bar
Association, the California Society for Healthcare Attorneys,
and the Association of Corporate Counsel.
Mr.
Dennis S. Diaz, Partner, Davis Wright Tremaine LLP
Mr. Diaz concentrates his practice in health law, healthcare
compliance, and healthcare transactional matters. Mr. Diaz
represents a wide variety of healthcare organizations, including
hospitals, physician organizations, integrated delivery
systems, ambulatory surgery centers, home health agencies,
hospices, and health plans, with an emphasis in regulatory,
compliance, and transactional matters. Mr. Diaz has been
named one of the country’s 12 Outstanding Hospital Lawyers
by Nightingale’s Healthcare News.
Mr.
John N. Fink, Senior Manager, ECG
Mr. Fink has been providing healthcare consulting services
since 1991. His experience in strategic and business planning,
operations improvement, and information technology provides
him with the skills necessary to evaluate and resolve the
complex strategic, financial, operational, and technological
issues facing healthcare organizations today. Mr. Fink has
significant experience working with hospitals, physicians,
and legal counsel to develop professional services agreements
and other contractual financial arrangements related to
hospital-based specialties, outpatient services, and medical
directorships.
The
moderator for this session is:
Mr. Kevin P. Forster, Principal, ECG
These sessions are complimentary to our clients, industry
colleagues, and other interested parties. ECG reserves the
right to deny access to those individuals who may pose a conflict
of interest to ECG.