The health care compliance plan has quickly moved from being an optional luxury to a mandatory requirement for helath care providers and health care companies. This is due to a variety of factors including that the government has made high…
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For physican owned hospitals in the United States, this is truly the best of times and the worst of times. Here's why . . .
The Center for Medicare and Medicaid Services (“CMS”), on July 2nd, published their thoughts relating to the impending Stark III Rules. In addition to certain specific proposed rules, CMS solicited comments on several areas of concern. These proposed Stark III…
The Center for Medicare and Medicaid Services (“CMS”), on July 2nd, published their thoughts relating to the impending Stark III Rules. In addition to certain specific proposed rules, CMS solicited comments on several areas of concern. These proposed Stark III…
Health care systems often develop medical director arrangements on an ad hoc basis as the relationships between the system and particular specialists evolve. Because these arrangements can differ greatly from specialty to specialty in compensation and responsilbilities, they can raise…
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During 1998 and 1999, the Office of the Inspector General ("OIG") issues a total of 33 advisory opinions. These advisory opinions cover a broad range of topics. Many of the opinions are extremely instructive to the health care lawyer in terms…
The Department of Health and Human Services Office of Inspector General ("OIG") recently issued final guidance on a host of issues relevant to voluntary compliance programs for small practices. Released September 25, 2000, the OIG Compliance Program Guidance for Individual…
Allegations of provider group boycott activity are increasing as health care professionals respond to the growing market power of third part payers and other manages care entities.
A recent New York State hospital transaction highlights the challenging problem which the Board of Directors of a not-for-profit institution faces in the context of a sales transaction.1 In Manhatten Eye, Ear & Throat Hospital ("MEETH"), the Court denied the…
Magnetic resonanace and other imaging ventures that include physician owners can be characterized principally into two types. First, there are imaging ventures that include only radiologists as owners.