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McBrayer Blogs
Showing 4 posts from 2019.
Companies—It May Be Time to Reevaluate Your Corporate Compliance Program
In April 2019, the United States Department of Justice (“DOJ”), Criminal Division, issued a guidance document entitled “Evaluation of Corporate Compliance Programs.”[1] This guidance updates standards the DOJ utilizes to investigate, charge, and negotiate criminal charges related to corporate crimes.[2] Although the DOJ recognizes that each company has its own set of unique risks, its investigations often include three common questions in assessing the effectiveness of a company’s corporate compliance program. More >
A Physician’s Guide to Employment Contracts with Hospitals and Health Systems
As hospitals and health systems continue moves toward clinical integration, more physicians are being employed by hospitals and health systems rather than practicing medicine in their own private practices. The trend toward direct hospital employment of physicians accelerated after 2012 and it appears that the trend will continue as both hospitals and physicians navigate regulatory, reimbursement, and operational challenges in the future. When considering employment by a hospital or health system, physicians should be mindful of various provisions that are often contained in physician employment agreements and how these provisions may impact the physician’s professional practice and personal life. Here are important issues to consider when evaluating whether to enter into an employment agreement with a hospital or health system. More >
A New Opportunity: Centers for Medicare and Medicaid Services Recognizes the Full Potential of Ambulance Crews and Services
In mid-February 2019, the Centers for Medicare and Medicaid Services (“CMS”), Innovation Center and the Department for Health and Human Services (“HHS”) announced a ground-breaking payment and medical services initiative for ambulance providers called “Emergency Triage, Treat and Transport” (the “ET3”). This new model is the first step in allowing providers of Emergency Medical Services to finally “take off the gloves” to fully utilize both their medical skills and unique patient knowledge to implement a more efficient and effective care model. More >
Compliance is Crucial
This article appeared in the December edition of MD-UPDATE, available at http://www.md-update.com/wp-content/uploads/2018/12/MD-Update-Issue-118/#?page=8
In the current legal enforcement environment, it is crucial that healthcare providers prioritize compliance initiatives and programs in order to avoid illegal practices that may result in large financial penalties and both criminal and civil liability. More >
