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HHS Advisory Opinion Approves Profit-Based Bonus Plan for Bona Fide Physician Employees

By Gretchen Heinze Townshend, Helen Suh, Timothy Fry, Kimberly J. Kannensohn, Kristen McDermott Woodrum, Natalie Galdos & Kristen H. Chang on October 30, 2023
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On Oct. 13, the U.S. Department of Health and Human Services Office of Inspector General issued an advisory opinion approving a physician practice’s proposal to pay bonuses to each of its employed physicians based on net profits derived from the facility fee generated by procedures the physician performed at the practice’s ambulatory surgery center.

Read on for analysis of this opinion and how the proposed arrangement avoids implicating the federal Anti-Kickback Statute.

Photo of Gretchen Heinze Townshend Gretchen Heinze Townshend

Gretchen’s practice focuses on corporate healthcare transactional work and regulatory matters. Her experience includes representation of various types of healthcare providers including hospitals, health systems, dialysis facilities, multi and single specialty medical practices, specialty hospitals, ambulatory surgery centers, and a variety of healthcare…

Gretchen’s practice focuses on corporate healthcare transactional work and regulatory matters. Her experience includes representation of various types of healthcare providers including hospitals, health systems, dialysis facilities, multi and single specialty medical practices, specialty hospitals, ambulatory surgery centers, and a variety of healthcare industry entrepreneurs, in sales and acquisitions, joint ventures, general corporate matters, contracting, securities, and regulatory matters.

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Photo of Helen Suh Helen Suh
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Photo of Timothy Fry Timothy Fry

Tim resolves clients’ thorny compliance and regulatory issues that make or break healthcare transactions and operations. He delivers practical, business-oriented solutions that clear obstacles, close deals, and protect enterprise value.

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Photo of Kimberly J. Kannensohn Kimberly J. Kannensohn

Kimberly focuses her practice on the provision of corporate, regulatory and compliance counseling to healthcare and life sciences companies. The cornerstone of her practice is providing guidance to clients regarding HIPAA and the HITECH Act, the Medicare and Medicaid fraud and abuse laws…

Kimberly focuses her practice on the provision of corporate, regulatory and compliance counseling to healthcare and life sciences companies. The cornerstone of her practice is providing guidance to clients regarding HIPAA and the HITECH Act, the Medicare and Medicaid fraud and abuse laws, the Stark Law, Medicare coverage and reimbursement rules, and state healthcare laws and regulations.

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Photo of Kristen McDermott Woodrum Kristen McDermott Woodrum

Kristen focuses on transactions and regulatory matters for healthcare industry clients as a partner in the national healthcare practice of McGuireWoods. Kristen anticipates potential issues and provides practical counsel to clients in structuring complex healthcare deals, including mergers, acquisitions, joint ventures, and other…

Kristen focuses on transactions and regulatory matters for healthcare industry clients as a partner in the national healthcare practice of McGuireWoods. Kristen anticipates potential issues and provides practical counsel to clients in structuring complex healthcare deals, including mergers, acquisitions, joint ventures, and other transactions and contracting arrangements. Clients across the industry rely on Kristen’s deep healthcare experience and business-focused approach.

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Photo of Natalie Galdos Natalie Galdos

Natalie focuses her practice on the healthcare industry, advising clients on transactional matters, mergers, acquisitions, private equity transactions and healthcare regulatory compliance matters.

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Photo of Kristen H. Chang Kristen H. Chang

Kristen assists clients in traversing regulatory, compliance, corporate transactional, and reimbursement issues related to the healthcare industry. She counsels clients on the federal Anti-Kickback Statute, Stark Law, Medicare policy, state fraud and abuse laws, state corporate practice of medicine laws, state licensure laws…

Kristen assists clients in traversing regulatory, compliance, corporate transactional, and reimbursement issues related to the healthcare industry. She counsels clients on the federal Anti-Kickback Statute, Stark Law, Medicare policy, state fraud and abuse laws, state corporate practice of medicine laws, state licensure laws, HIPAA, fee-splitting prohibitions, and other regulatory matters.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    The FCA Insider
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

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