It’s not uncommon for labs to place a phlebotomist in a physician’s office to collect and process samples for testing. While not strictly illegal, this practice raises bright red flags under kickback laws. So, it’s imperative to carefully vet your in-office phlebotomist arrangements to ensure they don’t cross any kickback lines. Here’s how. The Legal Risks of In-Office … [Read more...] about 5 Ways to Avoid Kickback Risks When Placing Phlebotomists in Ordering Physician’s Offices
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Compliance Tool: Model In-Office Phlebotomist Agreement
The following Model Agreement between a referring physician and a testing lab was created by Savannah, GA, lab compliance attorney Adam Walters and structured to minimize kickback liability risks to each party in accordance with the OIG 1994 Special Fraud Alert, which remains the definitive source of federal guidance on the subject. Speak to your attorney about adapting the … [Read more...] about Compliance Tool: Model In-Office Phlebotomist Agreement