Arrangements Reviews

In the complex regulatory and enforcement environment, health care organizations seek Strategic Management’s services to ensure their arrangements with physicians are compliant with the Federal Anti-Kickback Statute, Stark Law, and other legal authorities. We work with health care organizations and law firms to review and analyze their existing arrangements with physicians and their systems to identify potential risks.

Reviewing arrangements with physician and other referral sources is the best means by which to avoid implicating the Anti-Kickback Statute and Stark Laws, the number one enforcement priority for the DOJ and OIG. It involves evaluating whether the systems, controls and policies effectively manage the legal and regulatory compliance risks for health care organizations. Determining compensation for any party in a position to influence referral of business requires ensuring avoiding potential violations of laws. Strategic Management has unsurpassed expertise in this area and is engaged to work with health care organizations and law firms to review and analyze their existing arrangements with physicians and their systems to identify potential risks.

Physician and Focus Arrangements 

It is common business for health care organizations to enter into physician arrangements, on-call arrangements, leases and joint ventures. In doing so, it is important these arrangements comply with the Federal Anti-Kickback Statute and the Stark Law and align with fair market value and commercial reasonableness standards. Strategic Management examines physician arrangements and other arrangement types to determine whether they are in conformance to all applicable legal provisions.

Regulatory Compliance Arrangement Reviews

Strategic Management performs Arrangements Reviews that focus on the systems, controls and policies in place to manage existing, new and renewed arrangements. Arrangement Reviews evaluate whether the systems, controls and policies effectively manage the legal and regulatory compliance risks for health care organizations. Our health care compliance consultants prepare findings and recommendations to help improve systems, controls and policies.

In-Depth Compliance Reviews

Strategic Management has developed a proprietary review process of health care arrangements that addresses: 

• Initiating an arrangement;
• Establishing a business need;
• Reviewing and approving arrangements
• Tracking remuneration;
• Ensuring services are performed in accordance with the arrangement;
• Monitoring leased space, medical devices and/or patient care items in accordance with the arrangement; 
• Responding to suspected violations; and
• Auditing and monitoring the systems, controls and policies.