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Brad Broker

ASCs and the federal anti-kickback safe harbor

The primary concern is whether distributions to ASCs constitute disguised remuneration for referrals. Given the severity of the criminal and civil sanctions under the Anti-Kickback Statute, physicians need to structure these arrangements carefully and consistent with the ASC safe harbor and OIG’s position on health care ventures.

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Appraising PHC4’s infection report

Given the report’s methodological limitations, its accompaniment by new research minimizing the importance of those limitations, and its data displayed in a format that seems to encourage inappropriate comparisons of one hospital’s numbers to another hospital, the meaning and significance of the report become complicated questions.

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