On April 24, 2018, after
it self-disclosed conduct to OIG, Hartford Hospital in Connecticut, agreed to pay
$423,017.45 for allegedly violating the Civil Monetary Penalties Law provisions
applicable to physician self-referrals and kickbacks.
The OIG alleged that
Hartford Hospital provided remuneration to a medical practice in the form of
office space, where Hartford Hospital charged the practice rent at less than
fair market value. The remuneration created a financial relationship between
Hartford Hospital and the practice that caused Hartford Hospital to present
claims for health services that resulted from prohibited referrals in violation
of the Stark law.
Rental arrangements where there are patient referrals need to be reviewed for compliance with Stark and Anti-Kickback statutes. This case is an example of the high fines that can result. Luckily, the self-disclosure likely prevented more severe sanctions such as exclusion or criminal referral.
Posted by Tracy Green
Green and Associates
