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Physician Contracting and Compliance: To Disclose or Not to Disclose
December 7, 2011
By: Sarah E. Swank, Steven R. Smith, and S. Craig Holden
It has been over a year since the release of the CMS Stark voluntary disclosure protocol and fraud enforcement is “heating” up with the new OIG’s HEAT team. In reaction, many hospitals and health systems have begun fine tuning their compliance programs and auditing their billing data and financial relationships with physicians.
Steven R. Smith and Sarah E. Swank of the Ober|Kaler Health Care General Counsel Institute and Craig Holden, co-chair of Ober|Kaler's Health Law Group, presented a webinar exploring this topic. The speakers discussed best practices for both compliance programs and auditing to avoid downstream fraud and abuse issues. They also provided guidance on when and where to disclose problems.
Program materials are available at these links:
This is the second of a three-part series examining the hospital/physician relationship.
- Courting Physicians: Pros and Cons of Six Integration Models (October 20, 2011)
- Physician Contracting and Compliance: To Disclose or Not to Disclose (December 7, 2011)
- Disruptive Physicians: A Roadmap to Avoid Dangerous Behavior (January 18, 2012)
