Liverderm, LLC: Case Study
Assumptions
• LiverDerm, LLC, LLC meets the definition of a group practice as described by the Stark Law
See 42 C.F.R. § 411.352 for more information (attached)
• LiverDerm, LLC is a designated health services (DHS) provider
• Healthy Human Hospital (HHH) is an academic medical center
Introduction: Stark Law and Anti-Kick back (define)
Doctors Liverman and Doctor Derm,
Thank you for providing more information about your intentions with LiverDerm, LLC. I have researched your concerns, especially how your practice will be impacted with regards to the Stark Law, which in the simplest terms is a conflict of interest stature. The Stark Law will play a significant role on the way you do business and your affiliation with HHH.
The Stark Law …show more content…
As a group practice LiverDerm, LLC, PC would be advised to render services to HHH under the Group Practice Compensation. Compensation may not be based on the volume or value of referrals for DHS. Physician group members may be paid productivity bonuses based on services personally performed or ‘incident to’ services. A share of overall profits may also be paid under certain circumstances. The group practice must review their compensation structure to ensure that all requirements are met if they intend to take advantage of the IOAS …show more content…
The False Claims Act includes delibrate ignorance or reckless disregard to the truth. Civil penalties for false claims are up to $11,000 for each false claim, plus three times the amont of damages the government sustains from each claim. Violation may also lead to exclusion from Medicare and Medicaid (or other Federal health care programs). Damages may be brought by private persons, competitors or employees of a provider on behalf of the government. Private persons are entitled to a percentage of the monies
• LiverDerm, LLC, LLC meets the definition of a group practice as described by the Stark Law
See 42 C.F.R. § 411.352 for more information (attached)
• LiverDerm, LLC is a designated health services (DHS) provider
• Healthy Human Hospital (HHH) is an academic medical center
Introduction: Stark Law and Anti-Kick back (define)
Doctors Liverman and Doctor Derm,
Thank you for providing more information about your intentions with LiverDerm, LLC. I have researched your concerns, especially how your practice will be impacted with regards to the Stark Law, which in the simplest terms is a conflict of interest stature. The Stark Law will play a significant role on the way you do business and your affiliation with HHH.
The Stark Law …show more content…
As a group practice LiverDerm, LLC, PC would be advised to render services to HHH under the Group Practice Compensation. Compensation may not be based on the volume or value of referrals for DHS. Physician group members may be paid productivity bonuses based on services personally performed or ‘incident to’ services. A share of overall profits may also be paid under certain circumstances. The group practice must review their compensation structure to ensure that all requirements are met if they intend to take advantage of the IOAS …show more content…
The False Claims Act includes delibrate ignorance or reckless disregard to the truth. Civil penalties for false claims are up to $11,000 for each false claim, plus three times the amont of damages the government sustains from each claim. Violation may also lead to exclusion from Medicare and Medicaid (or other Federal health care programs). Damages may be brought by private persons, competitors or employees of a provider on behalf of the government. Private persons are entitled to a percentage of the monies