Biomedical subjects
Gary W Herschman
Publications and source records attributed to Gary W Herschman.
How to structure a compliant hospital-physician ASC.
Three recent advisory opinions issued by the HHS Office of Inspector General (OIG) provide insight into how the OIG is likely to view a proposal by a hospital and physicians to develop a jointly owned ambulatory surgical center (ASC). In assessing whether the proposed ASC meets the 13 requirements to qualify for the ASC safe harbor under federal fraud and abuse law, the OIG will likely insist that the arrangement strictly comply with some requirements, such as the one defining the necessary characteristics of physician owners, while allowing more leeway in compliance with others.
OIG 2003 work plan ready for SNFs.
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When QA documents are privileged.
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Keeping pain control out of the courts.
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Providers find safe harbor for discounts.
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