Nonprofit Compliance

  • 1.  Hospitals and Physician Recruitment

    Posted 05-25-2015 11:06 AM
    This message has been cross posted to the following eGroups: Nonprofit Compliance and Health Care Systems .

    Hi all,

    I am looking for some specific direction, if available, to help me answer the question of whether a not-for-profit hospital may assist physicians in the area with provider recruitment.

    If you have any resources to suggest, I would appreciate it, thank you!


    Tricia Owsley JD
    Progressive Health Systems

    Default Blank

  • 2.  RE: Hospitals and Physician Recruitment

    Posted 05-26-2015 10:40 AM

    The federal register lists the Stark exceptions in 42 CFR 1001.952.  Under subsection "n" there is the explanation of the exception for Physician Recruitment.  Basically, everything has to be spelled out in a written agreement.  I work for a nonprofit hospital system.  The exceptions are the same for profit and not-for-profit companies.  But to be sure, you should check your state's Stark and Anti-Kickback equivalents to the federal laws.


    Jim Bowman, CHC

    System Director, Compliance

    Description: VBXVANYQIUTU.IMAGE_8.BMPDescription: Description: VBXVANYQIUTU.IMAGE_8.BMP


    Office of Compliance, Audit and Privacy (OCAP)

    80 Seymour Street

    Hartford, CT. 06102

    PHONE: 860-972-4093

    CELL:  860-214-6147

    FAX: 860-545-3550



    If you have a compliance or privacy concern, contact the HHC ComplianceLine .

    1.855.HHC.OCAP    │


    Working Together, Doing the Right Thing


    This message originates from Hartford HealthCare. The information contained in this message may be privileged and confidential. If you are the intended recipient you must maintain this message in a secure and confidential manner. If you are not the intended recipient, please notify the sender immediately and destroy this message. Thank you.


    This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, or an employee or agent responsible for delivering the message to the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message, including any attachments.

    Default Blank