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Compliance Perspectives: 5 Ways to Avoid Kickback Risks When Placing Phlebotomists in Ordering Physician’s Offices

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 Phlebotomist Arrangements The Anti-kickback statute (AKS) bans labs from offering or providing physicians anything of value to induce or reward the referral of patients covered by Medicare, Medicaid and other federal health care programs. The Stark Law and state antikick laws impose similar restrictions. The problem is that while you might not think of it as such, placing a phlebotomist inside the office of an ordering physician may constitute the kind of… . . . read more.

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 model for your own use.


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