Teton Regional Healthcare (TRH) is a healthcare system located in Jackson, WY. It consists of a main hospital (200 beds), a small critical access hospital (25 beds), an ambulatory surgical center, a freestanding imaging center, skilled nursing facility, a mental health and substance abuse facility, and 20 primary and specialty physician clinics. A subsidiary of TRH is Teton Physician Network (TPN), which consists of 220 employed physicians covering several different specialties including primary care, orthopedics, cardiology, oncology, and neurology to name a few.

Steven Moffitt (Steve) is the Chief Financial Officer for TPN. He was hired six months ago, having relocated from the Midwest. His wife grew up near Jackson, WY.

Steve contacts Jennifer Cohen (Jen), TRH's Chief Compliance Officer (CCO) to meet and discuss some concerns he recently identified. After meeting with Steve, Jen learns of four potential Stark law issues regarding TRH's financial relationships with some of its physicians (TPN employed and independent contractor specialists).

Steve reports to Jen an issue relating to excessive physician compensation for some of Teton Regional Center's (TRH's) contracted physician specialists.

In one example, Steve explains that TRH has rewarded physicians with retroactive increases in their compensation based on referral patterns and not work actually performed. Steve cites to Dr. Jack Anderson's contract as an example. It was amended in September 2020 to increase his base compensation by $50,000, but the amendment language made it effective on January 1 2019.

In another example, Steve mentions concerns related to some of the medical director contracts. More specifically, he tells Jen that last month he objected to payments made to physicians for medical director services without any confirmation or documentation of services actually performed. Steve cites to Dr. Tom Reynolds, the medical director of TRH's cardiac cath lab. Dr. Reynolds was paid $150,000 YTD for medical director services with no documentation of work performed.

As the Personal Services Arrangements Compliance Specialist on Jen's team, you are to only address Steve's allegations related to violations of Stark specific to compensation to contracted physicians.

1. Based on what Steve reported, what concerns about the lack of medical director services documentation would you cite? Why or Why not? 

Answer rating: 100% (QA)

Answer Based on Steves report regarding potential Stark law issues related to physician compensation there are indeed concerns about the lack of docum... View the full answer