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Video: Antifraud Compliance Getting More Complex for Hospitals
Date:4/21/2008

ng its own internal investigation should focus on potential problem areas such as (a) physician office space leases, (b) medical directorships and on-call agreements; (c) recruiting agreements; and (d) joint ventures and other partnerships that include physicians.

Hospitals may need to work with outside counsel or other consultants to manage an initial investigation of their hospital-physician contractual arrangements and to design a robust system to monitor them in the future.

The skills that make a good doctor do not necessarily translate to good record keeping. Hospitals may need to provide additional resources to make ongoing compliance and monitoring as effortless as possible for the physicians they have contractual arrangements with.

Monitoring Hospital-Physician Contractual Arrangements

-- Healthcare fraud estimated at as much as $200 billion annually

-- Office of the Inspector General enforcing federal anti-fraud and

self-referral statutes aggressively -- with more than a dozen

settlements in the past three years

-- "Whistleblower" statutes give employees a strong incentive to report

abuses -- Potentially up to 30% of any penalties the government

collects as a reward

-- About 500 hospitals may be subject to extra requirements to report all

contractual relationships with physicians

-- Self-reporting "safety valve" can reduce penalties and ongoing

compliance burdens for hospitals that find and disclose violations

-- As "gatekeepers" into the medical system, physicians have many ways

they can be connected to hospitals, imaging centers, clinics, durable

medical equipment suppliers -- so documenting all possible arrangements

is a big challenge

-- Hospitals may need help examining existing arrangements and required

documentation and to set up workable monitoring programs going forward

About the Deloi
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SOURCE Deloitte
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