In addition, the letter announces an initiative promoting the use of the SDP to resolve civil monetary penalty (CMP) liability under the physician self-referral (Stark) and anti-kickback statutes for financial arrangements between hospitals and physicians. The range of CMP damages available goes from "number and dollar value of improper claims" under Stark to the "number and dollar value of improper payments or remuneration" under anti-kickback. The letter seems to indicate that the OIG will "settle the SDP matters for an amount near the lower end of the continum, i.e., a multiplier of the value of the financial benefit conferred by the hospital upon the physician(s)."
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