When Physician Pay Becomes a Compliance Problem: What Hospital Leaders Need to Know

Foley partner Larry Vernaglia, co-chair of the firm’s Providers of Health Care Services Area of Focus, will speaking on the panel “When Physician Pay Becomes a Compliance Problem: What Hospital Leaders Need to Know” on March 25 during the New Jersey Healthcare Financial Management Association’s Webinar: Nothing but the FACTs on Finance, Accounting, Capital & Taxes in Healthcare.

This session will focus on the Department of Justice and Office of Inspector General enforcement trends related to physician compensation and arrangements tied to referrals — and why this is increasingly a finance problem, not just a legal or compliance issue. For hospital CFOs and finance leaders, physician compensation is typically the largest controllable expense on the income statement. What has changed over the last several years is that compensation structure now directly impacts revenue integrity.

This session will cover:

• Team-based compensation.
• Fair Market Value (FMV) determinations — especially when providers exceed the 75th percentile.
• Downstream revenue scrutiny.
• The role of Advanced Practice Providers (APPs) and incident-to-billing.