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Medicare-Medicaid
Anti-Fraud and Abuse Amendments of the 1997 Balanced Budget Act apply
to virtually any health care contract. The anti-kickback provisions
of the statute prohibit an individual from wittingly and willfully compensating
in an obvious form (e.g., money, rebate, in-kind services, free-bees,
etc.), or in an indirect or disguised form for referring a patient for
the furnishing or arranging of a service (e.g., a referral) covered by
Medicare or Medicaid.
1)
This statute was designed
A) To prevent arrangements that limit the freedom of
the patient to choose a provider, and
B) To prevent unnecessary utilization, and to reduce
costs to federal programs by decreasing or eliminating medically unnecessary
procedures or services.
2) Any person-payer and receiver of such prohibited remuneration-may
be guilty of a felony for violating this statute
A) Upon conviction they will be excluded from further
participation in Medicare and Medicaid, and they will be fined or imprisoned,
or both.
3) To qualify for safe harbor exemptions, there must be:
A) A formal agreement.
i) It must specify
all full-time or part-time services to be provided
ii) It must be set
out in writing;
iii) It must be
signed and dated by all involved parties
iv) The term of
the agreement must not be less than one year
v) In all cases,
fair market value applies, however,
vi) Compensation
does not have to take into account the value or volume of the referrals.
4) Safe Harbors:
A) The waiver of deductibles and coinsurance
B) Reasonable discounts for items or services
C) Certain investment interests by doctors
D) Personal and management service contracts
between physicians and institutions
E) If the services are provided on a part-time
basis, the schedule of services and payments for services must be set
in advance.
F) Space and equipment rental arrangements
G) Sale of medical practices
H) If, however, a business transaction addresses
several types of payments covered by more than one safe harbor, all
elements of each safe harbor must be met to ensure compliance.
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