Feds Warn Physicians About Fraud Risk In Some Compensation Structures

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. Compensation arrangements may violate the anti-kickback statute if even one purpose of the arrangement is to compensate the physician for past . . .