Let’s assume for now that the provider is a healthcare licensee and that no Medicare or Medicaid reimbursement is involved. Let’s first talk about federal Stark and anti-kickback legal rules. It’s important to read the rules carefully and apply them to the facts.

The answer to the fee-splitting question depends both on the kind of provider, and on state law – and the other underlying circumstances, such as whether the healthcare provider is an employee or independent contractor.įor example, some statutes do not apply fee-splitting prohibitions to massage therapists, but do apply the prohibitions to medical doctors, chiropractors, and acupuncturists. The client may be the venture owner / entrepreneur, the medical director for a medical group, or a practitioner who is a medical doctor or osteopathic physician, or a chiropractor, acupuncturist, homeopath, massage therapist, or other clinical care provider. “I provide medical (or acupuncture, chiropractic, osteopathic, massage) services on an hourly basis and get paid a percentage of revenues in return.” Is that fee-splitting? The fee-splitting question is a typical one that clients bring to our firm. MANAGEMENT SERVICES ORGANIZATIONS (MSOS).HEALTHCARE FACILITIES (HOSPITALS, LABS, DME, IMAGING).DIETARY SUPPLEMENT & NUTRACEUTICAL COMPANIES.CONCIERGE & DIRECT PRIMARY CARE MEDICAL PRACTICES.COMPLEMENTARY & INTEGRATIVE MEDICINE PROVIDERS.BIOTECHNOLOGY & LIFE SCIENCES COMPANIES.BEHAVIORAL & MENTAL HEALTHCARE PROVIDERS AND LIFE COACHES.ANTI-AGING & FUNCTIONAL MEDICINE PRACTICES.Medical Device & Mobile Medical App Issues.Management Services Organizations (MSO) Issues.M&A (Acquisitions & Sales of Healthcare Businesses).Fraud & Abuse (Anti-Kickback, Fee-Splitting, Stark).

Medical office sharing agreement