For hospitals and health systems, compliance with the health care fraud and abuse laws focuses on three critical regulatory requirements for physician compensation: fair market value, commercial reasonableness and the prohibition on “taking into account” the volume or value of a physician’s referrals. These regulatory requirements have been called the “Big 3.” In this session, panelists will discuss physician compensation trends, including the “Big 3” regulatory requirements as they stand today, recent enforcement actions and developing best practices.
Learning Objectives:
- Identify the “Big 3” regulatory requirements of FMV, commercial reasonableness, and volume/value.
- Describe recent enforcement actions, areas of potential risk, and lessons learned.
- Evaluate process and documentation that support compliance.