By MARIA TODD
- Sublease Agreements: Hospitals cannot enter into sublease arrangements with physicians in order to host town hall meetings with Medicare, Medicaid, or otherwise insured beneficiaries in the physicians’ offices. The rental value for these arrangements must be at fair market value and cannot take into consideration the potential volume or value of referrals from the physicians to the hospital. Additionally, the rent cannot be paid on a monthly basis regardless of whether or not the hospital conducts any meetings in the physicians’ offices that month.
- Reduced or discounted office space: Leasing or space use that is charged at less than fair market value in exchange for any cash or other valuable consideration is not permitted.
- Shared Marketing Agreements: The hospital cannot enter into Shared Marketing Agreements with physicians in order to increase the physicians’ patient base and revenues. This is different than marketing bundled case rates, but the rules for marketing bundled case rates must be followed meticulously. There are many inexperienced consultants suggesting and recommending strategies that are non-compliant. The offers cannot include inducements that raise admissions or utilization for the hospital in an inappropriate manner.
- Vendor Marketing Agreements: Vendor Marketing Agreements can become problematic similar to Shared Marketing Agreements if there is not cost-sharing by the physicians.
- Medical Directorship Agreements: The Medical Director Agreements cannot be based upon a target number of referrals/admissions to be made to the Hospital by the physicians. Otherwise basing offers of consideration for the position of Medical Director appointment if the physician refers or admits a certain number of patients each month/year.
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