Sentencing is set for August and the convictions will likely be appealed, but the story of the case accentuates the changing risks in modern healthcare. While the specific arrangements in Kansas City may only be instructive in the extreme, numerous pieces of the story may be reflective of arrangements that are not that uncommon, as well as documentation failures that inevitably occur. In addition, the case highlights lessons that may too often be overlooked. The latter part of this article provides more detailed facts and circumstances of the U. S. v. Anderson, et al. case as they have been reported in the public media. Documentation must support that physician effort was in fact expended, and that such services were in proportion to the payments.
Services involve both time expenditure as well as work product in the form of reports, records, etc.
Any connection between payment for services and the reality of admissions or referrals is presumptively problematic. Document, document, document. A written understanding of service requirements is essential, as well as periodic evaluation of whether the services are being performed. Payments based on actual hours worked and documented can be one option. Hospital management and governance should have independent confirmation of the appropriateness of the payment relationship.