The facts are that a nonprofit coalition provides psychodynamically-oriented psychotherapy at free or reduced prices to individuals who meet financial and clinical criteria. The therapy generally is provided by advanced psychiatric residents from local teaching facilities. The residents donate their time, as do the faculty who provide clinical training and supervision. This arrangement enables the participating institutions to provide training to the residents that was otherwise only available if the residents arranged and paid for the training outside their residency program. No third party payers are billed for the services.
Most patients are self-pay and pay on a sliding fee scheduled based on income and family size.
Medicare beneficiaries are not charged for the services. The OIG also found that the additional training opportunities for advanced psychiatric residents is a legitimate business purpose for institutions to agree to participate in this arrangement.