Providers will often pay physicians for serving in important administrative roles within the organization. Compensation for administrative services can create risk to the organization under multiple laws, including the Physician Self-Referral Law (a/k/a “Stark Law”) if the compensation paid to the physician for administrative services is not fair market value and reasonable. Last year, a regional health system and the individual physicians it contracted with paid over $69 million to settle False Claims Act allegations which stemmed, in part, from allegations that the health system paid physicians for medical director services that did not comply with the Stark Law.
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To ensure arrangements with physicians for administrative services comply with the Stark Law, providers should maintain documentation substantiating that the organization needs the administrative services and the amount paid for administrative services is fair market value. Our podcast this week goes into more detail on the importance of maintaining documentation of physician administrative services for Stark Law Compliance.
Included with this episode, as part of our many free resources from the show, we welcome you to download the monthly time documentation template below:
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