Salary negotiations are always fraught with emotion. But imagine a world where you have to worry that your boss might pay you too much. Sounds crazy. But this is exactly the kind of concern that most hospitals and doctors have to confront.

In June 2015, the Department of Health and Human Services (HHS) issued an “alert” about its concern that hospitals are overcompensating doctors in order to pay illegal kickbacks. HHS is suspicious of arrangements where hospitals appear to overpay doctors in exchange for patient referrals. Typically, such alerts are written at a time when an agency is developing cases that fit a consistent pattern. Indeed, in the six months since the alert, the HHS has brought a number of cases involving hospitals allegedly overcompensating physicians. The cases provide a guide to the key areas of concern for hospitals and physicians.

The HHS-OIG Fraud Alert

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