Fraud and Abuse

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As the head administrator for Sundown Community Hospital, I have been directed by the board to enter into a joint venture agreement with Central Park medical group. I am aware that this medial group treats a patient population of which 60% are covered by Medicare.


This is essentially what I am being asked to do; I am being asked to pay "monthly bonuses" to the Central Park Medical Group in order to form a business arrangement in which patients of the Central Park Medical Group are sent to my establishment, Sundown Community Hospital. In addition, it seems that the board as well as myself are fully aware of the fact that 60% of the Central Park Medical Group patients are covered by government health coverage. This is obviously why the board is eager to seal this deal with the medical group.
The fact that this is a joint venture agreement makes some of the facts a bit subject to interpretation as the Board of Medical Directors has implemented certain rules depending on the state. Anti-kickback statutes specifically state that income that may surface from joint venture activities must be compensation for services rendered. The "bonuses" given to physicians in the joint venture agreement between my organization and the medical group in question is very clearly not for any purpose but as referral incentive.
The Medicare and Medicaid Protection Act of 1987 clearly state that the type of actions described by the board to me as the administrator would qualify as a federal offense punishable with fines of up to $25,000 as well as other possible sentencing. ...
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