A recent enforcement action involving a New York hospital system offers a powerful reminder that physician agreements are only as strong as their execution.
In the latest Deeper Than the Headlines video, CJ Wolf walks through allegations that a hospital system paid more than $4 million to an oncology practice through multiple agreements—payments the government claimed violated the Anti-Kickback Statute. The case ultimately resulted in a $616,000 settlement.
According to the allegations, the agreements included medical directorships for proposed cancer centers and management of an intraoperative radiation therapy service line. The issue wasn’t just the contracts themselves—it was the lack of evidence that the work outlined in those agreements was actually performed. Missing or nonexistent time records made it difficult to demonstrate that payments were tied to legitimate services rather than patient referrals.
This case highlights a recurring compliance risk: organizations may invest significant time ensuring agreements are legally sound at signing, but fail to monitor whether those agreements are followed in practice. Without clear documentation, tracking, and oversight, even standard arrangements can raise red flags.
The key lesson is simple but critical: compliance doesn’t stop once an agreement is approved. Ongoing monitoring, documentation, and accountability are essential to demonstrate that physician arrangements are fair, legitimate, and defensible.
Healthicity
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