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Click here to view a pdf of the Winter 2010 issue of Corridors.

In This Issue

Money Talks, But Who’s Listening?
Money talks, and for hospitals and physicians this can become a real problem when negotiating a fair-market-value compensation arrangement. Hospitals and physicians negotiating compensation arrangements may have more people “listening into” their discussions than they may want or even realize. The federal case of United States of America ex rel. Michael K. Drakeford, M.D. v. Tuomey d/b/a Tuomey Healthcare System, C.A. No. 3:05-CV-2858-MJP, provides hospitals and physicians with insight into how the government views compensation under employment contracts.

T Minus 60 Days and Counting: CMS’s New Repayment Deadline
The Basics. The Patient Protection and Affordable Care Act, Public Law 111-148 (Act), creates new potent requirements for providers and suppliers to return Medicare and Medicaid overpayments. Subsection 6402(d)(1) of the Act says: If a person has received an overpayment, the person shall…

Self-Disclosure Déjà Vu?
The Voluntary Self-Referral Disclosure Protocol (SRDP) recently released by the Centers for Medicare and Medicaid Services (CMS) looks remarkably familiar. The new SRDP permits hospitals and other providers who believe that they are or might be providing services in violation of the federal Stark physician self-referral law (42 U.S.C. § 1395nn) to disclose such actual or potential violation to CMS in the hopes of resolving the matter as favorably as possible.

TriCare Network Contracts Create Affirmative Action Obligations for Hospitals
The Office of Federal Contracts Compliance (OFCCP) has made no secret of its desire to impose affirmative action obligations on hospitals. It moved quite a bit closer to this goal last month by winning a case against a hospital that had signed a TriCare network contract. In OFCCP v. Florida Hospital of Orlando, the hospital challenged OFCCP’s jurisdiction over it, and the administrative law judge ruled in OFCCP’s favor.

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