tci Outpatient Facility Coding Alert - 2018 Issue 1

Compliance: Determine the Kickback Status of Your Marketing Plan

Are you marketing the physicians or the surgery center? The line between promoting your center's services versus individual physicians can be murky. To clear things up, ask yourself questions like the following, according to attorney Kim C. Stanger of Holland & Hart LLP: Is your marketing saving the physician money they would normally spend to promote their own practices? Does the marketing focus on what your facility does or what the physician's practice does? For example, does it mention physician services that are unrelated to your surgery center? Does the marketing contain specific information about the physician's private practice...

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