Physician Relocation Program

Are You in Compliance?

The Office of the Inspector General (OIG) issued “An Open Letter to Health Care Providers” on April 25, 2006 offering self disclosure guidance on the federal physician self-referral law  (referred to commonly as “Stark”). This letter reflects OIG’s increasing flexibility in resolving past Stark violations when self-disclosed. However, tread carefully. The Center for Medicare  and Medicaid Services (CMS) and the Department of Justice (DOJ) also have jurisdiction and they have not yet offered comparable guidance.

In light of the Tenet Alvarado case (see article below on U.S. versus Weinbaum) it is strongly recommended that you audit all past relocation and recruitment arrangements, assess your liability, and seek legal counsel on how to approach the various agencies.  Next, make sure you’re compliant with all present and future contracts