Anesthesia Management Careers Resources About Us Why LifeLinc? Contact PAY BILL REQUEST PROPOSAL Exploring Anesthesia Business Models for ASCs Tuesday, January 29, 2019 Exploring Anesthesia Business Models for ASCs By Eric Callan, CRNA, DNAP DISCLAIMER: The information provided in this article is intended to provide general guidance on matters of interest only. The application of the information provided below may vary widely based on the specific facts involved in each situation. Considering the changing nature of laws, rules, and regulations there may be exceptions or other developments not considered in this article. As such, LifeLinc Anesthesia is providing this information in the understanding that the authors and publishers are not rendering legal or other professional counsel. Seek legal advice regarding your specific anesthesia arrangement as failure to do so can have serious criminal and civil penalties. Examining the Anti-Kickback Statute When considering the varying business models employed in a joint venture between an anesthesia group and an ASC, the two parties should enter arrangements that are advantageous to both sides. However, before opening discussion, a careful analysis should be conducted to ensure the business model chosen does not violate the federal Anti-Kickback Statute and rules established by the U.S. Department of Health and Human Services, Office of Inspector General (OIG). The Anti-Kickback Statute (42 U.S.C. Section 1320a-7b(b)) makes it a criminal offense to knowingly and willfully offer, pay, solicit, or receive any remuneration to induce or reward referrals of items or services reimbursable by a federal health care program. Where remuneration is offered, paid, solicited, or received purposefully to induce or reward referrals of items or services payable by a federal health care program, the Anti-Kickback Statute is violated. Criminal penalties for violating the Anti-Kickback Statute may include fines, imprisonment, or both. The OIG has provided a number of “safe harbor” regulations to detail differing payment and business practices that will not be treated as breaches of the statute. These “safe harbors” exist for personal services contracts that meet all of the following seven conditions: CRNA Anesthesiologist N/A Location 3340 Players Club Parkway, Suite 350 Memphis, TN 38125 901-844-1590 866-362-6963 Billing Inquiries 901-930-0182 LifeLinc Anesthesia Management Careers Resources About Us Why LifeLinc? Contact Follow Us Linkedin Facebook Instagram Twitter Web Design by Speak Privacy Policy Terms of Use