MGMA 2017 Annual Conference

Sessions Speakers Exhibitors Products Press Releases Show Specials Floor Plan

Paying for Call: Balancing Competitiveness with Regulatory Compliance (Room Room 303)

With increased scrutiny on call coverage compensation, it is imperative that organizations ensure that call coverage arrangements are both reasonable and consistent with fair market value. The OIG has clearly stated that there are essentially two main criteria to test whether a given on-call compensation arrangement passes existing regulatory scrutiny. First, the compensation must be "fair market value in an arm's-length transaction for actual and necessary items or services." Second, the compensation should not be "determined in any manner that considers the volume or value of referrals or other business generated between the parties." The OIG has indicated that there is significant risk associated with call coverage arrangements that are not structured appropriately and such arrangements could be used to "disguise unlawful remuneration." Guidance on how to establish call coverage arrangements to ensure financial and regulatory compliance while also balancing the organization's need to be market competitive will be presented as well as addressing the multiple challenges organizations face in assessing the impact various factors have on the market data.