ANTI-KICKBACK

Compliance Tool: Model In-Office Phlebotomist Agreement

The following Model Agreement between a testing lab and a referring physician was created by Savannah, GA, lab compliance attorney Adam Walters and structured to minimize kickback liability risks to each party in accordance with the OIG 1994 Special Fraud Alert, which remains the definitive source of federal guidance on the subject. Speak to your attorney about adapting the model for your own use.

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