Eight common mistakes when determining FMV for physician clinical services compensation
Written by Caroline Dean
Published by Becker's hospital Review
As physician compensation reform and regulatory scrutiny continue to be a focus of attention, parties are putting forth a more concentrated effort to ensure physician compensation arrangements are considered fair market value (FMV).
The regulatory environment surrounding physician compensation can often be difficult to navigate, while also trying to balance making competitive offers and attracting and maintaining top talent. The most significant laws guiding physician compensation arrangements are the federal Anti-Kickback Statute (AKS) and the Physician Self-Referral Law (Stark Law). To be compliant with these regulations, physician compensation must be set at FMV or risk potential for qui tam lawsuits, high dollar fines or even criminal charges. This article covers common mistakes that could potentially lead to violations of AKS or the Stark Law.
Eight Common Mistakes
The following list includes eight common mistakes that could lead to physician clinical services compensation that is inconsistent with FMV. While the following is not a comprehensive list, the mistakes discussed are important to avoid when establishing compensation for clinical services:
