Furnishing Your Compliance House: OIG Risk Areas. Marie C. Infante, Sr. VP, Chief Compliance Officer, Golden Living & Affiliated Companies Ken Burgess, Esq. Poyner Spruill, LLP. Furnishing Your Compliance House. Our “house” analogy Structural aspects of compliance program (written)
Marie C. Infante, Sr. VP,
Chief Compliance Officer,
Golden Living & Affiliated Companies
Ken Burgess, Esq.
Poyner Spruill, LLP
Establishes criminal penalties for
Offering OR providing OR receiving
For the referral of business paid for
By Federal healthcare programs
Implications for healthcare reform efforts?
Joint ventures or relationships intended to increase efficiency and produce cost-savings may induce referrals
May also induce underutilization
Uncertainty of enforcement
Priorities of the local US Attorneys Office
Personality of the particular prosecutor
Uncertainty of the enforcement climateAKS Anxiety
Can be anything of value
Free or below fair market value services or rent
Number of Medical Directors
Routine waiver of co-payments
Pricing arrangements for goods and services
“value added” services
Bundled paymentsWhat is Remuneration?