I received a lot of questions/comments on yesterday's email about billing for outpatient services at the hospital, including:

    Does the doctor pay "rent" to the hospital? What arrangements has he/she made? Does the doctor pay for supplies?  If no, the scenario that is posed seems almost "illegal" and I cannot imagine any hospital allowing this
to occur.
    As the above commentator also indicated, sometimes a simple billing question opens a whole other can of worms, which is why I am addressing the above concerns in today's email.  

    The above assertion is correct that a physician performing unrelated outpatient services at a hospital would, in fact, be required to have a space rental agreement in place in the form of a lease or license agreement. Failing to have a defined, fair market value, written relationship between the parties would constitute an illegal arrangement whereby either party would potentially be receiving a form of a "kickback" for use of the space or services rendered.  As a doctor, with all professional relationships you enter into, it is strongly advisable, and required in most instances, that such a relationship be in writing and determined at fair market value, as well as qualify under those certain requirements for each individual circumstances.  

    Remember:  Should your practice be audited or investigated, the likely question that will be asked to you is "show me the money" and if reimbursement received for your services rendered are being paid out in a way that is not transparent, defined at fair market value and in writing, you will be increasing your likelihood of liability and exposure.  


For additional information on this topic, contact Jennifer Kirschenbaum at (516)-747-6700 ext. 302 or at Jennifer@Kirschenbaumesq.com.


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