Fraud Alert: Physician Compensation Arrangements May Result in Significant Liability

On June 9, 2015, the Office of the Inspector General (OIG) for the federal Department of Health and Human Services (HHS) issued a fraud notice warning physicians that certain compensation arrangements could be viewed as fraud. The OIG notice called out compensation for medical directorships as an example of how the OIG would view arrangements that failed to reflect fair market value for “bona fide services that the physicians actually provide” as possibly violating the anti-kickback statute. The notice presents specific scenarios and the OIG evaluation of fraud risk in each . . .