In furtherance of the National Cybersecurity Strategy announced March 2023, HHS has released an Introduction to the Strategy of the U.S. Department of Health and Human Services for Healthcare Sector Cybersecurity. Click here for the PDF.
January 2024
False Claims Act (FCA) Liability for Physician Compensation Exceeding Fair Market Value (FMV)
By Michael Cassidy on
Posted in Articles
When negotiating physician compensation issues, hospitals frequently rely upon the premise they must pay fair market value compensation in order to comply with the provisions of the Stark Act prohibiting referrals in exchange for compensation, and sometimes non-profit inurement issues.
Although the prohibitions are clear, determining what constitutes fair market value is often not. Provisions…