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 … [Read more...]

ANTI-KICKBACK

Compliance Perspectives: 5 Ways to Avoid Kickback Risks When Placing Phlebotomists in Ordering Physician’s Offices

It’s not uncommon for labs to place a phlebotomist in a physician’s office to collect and process samples for testing. While not strictly illegal, this practice raises bright red flags under kickback … [Read more...]

COMPLIANCE GUIDANCE

Compliance Perspectives: Avoid Kickback Liability by Steering Clear of MD Processing Fees

Editor's Note: Two months ago, we talked about paying referring physicians a fee for collecting and processing blood, urine, tissue and other specimens. (G2 Compliance Advisor, Oct. 9, 2018, p. 1). … [Read more...]

COMPLIANCE GUIDANCE

Compliance Perspectives: Managing Kickback Liability Risks of Specimen Processing Fees

It's common practice for labs to pay physicians a fee for collecting and processing blood, urine, tissue, and other specimens from the patients they refer to your lab for testing. While this might … [Read more...]

COMPLIANCE PLANS

TOOL: Model Specimen Processing Fees Compliance Policy

Here's a Model Policy your lab can adapt to ensure that specimen processing fee arrangements with referral sources don't violate the Anti-Kickback and Stark laws. … [Read more...]

PAMA

Proposed 2019 Medicare PFS: The 5 Things Labs Need to Know

On July 12, CMS issued the proposed 2019 Medicare physician fee schedule (PFS), with comments scheduled to end on Sept. 10. Takeaways: 1. Physician Payment Rates  CMS is proposing a 0.25% increase … [Read more...]

ANTI-KICKBACK

Compliance Perspectives: New Stark Rules Offer Some Physician Kickback Relief but Not Nearly Enough

As a lab compliance officer, you have better things to do with your time than read government budget bills. But what you do need to know is that the new federal Bipartisan Budget Act of 2018 includes … [Read more...]

FALSE CLAIMS

Case of the Month: Judge Who Said Labs Must Independently Verify Medical Necessity Takes It Back

"That CAN'T Be Right: Court Says Labs Must Independently Verify Medical Necessity of M.D. Ordered Tests" That was the headline we used in reporting a highly disturbing federal court … [Read more...]

FALSE CLAIMS

That CAN’T Be Right: Court Says Labs Must Independently Verify Medical Necessity of M.D. Ordered Tests

Based on the enforcement track record, if your lab ever gets charged with falsely billing Medicare for lab tests, failure to document the medical necessity of the ordered tests will be the reason. … [Read more...]

COMPLIANCE CORNER

Spot the Compliance Mistake(s): Customized Test Panels & Medical Necessity

SITUATION As a convenience to clients, Nonexistent Laboratories (NL) offers medical groups the option of designing their own customized test panels. NL requires the medical director of the group to … [Read more...]


(-00000g2)