B09 – How to Avoid Committing Healthcare Fraud While Balancing Toxicology Revenue with Treatment Program
Saturday, August 20 | 10:15 am – 11:45 am
Venus Caruso, Esq.
Jeffrey Lynne, Esq.
Today, many owners of substance abuse treatment centers have either opened their own toxicology laboratory or are contemplating whether they should. The reasons for their wanting or thinking about doing so vary, including reinvesting the revenue realized from toxicology testing back into their treatment programs to help improve or expand patient care. However, the “how” and “why” of toxicology revenue tend to become obscured in the modern treatment paradigm and can lead, in some instances, to violations of health care regulatory and criminal laws caused by what regulators and insurance companies want to characterize as fraudulent behavior or over-utilization of services. In many instances, jointly-held treatment programs and toxicology service providers are simply unaware how to legally secure and reimburse referral sources, or what is deemed “appropriate” nature or frequency of testing. This presentation will educate the audience on how to avoid healthcare fraud under common ownership arrangements by reviewing applicable laws including illegal kickbacks, patient brokering, illegal fee-splits, fraudulent and abusive testing, medical necessity, and marketing and employment arrangements.
Upon completion of this course, participants will be able to:
- Identify legal behavior commensurate with entering into agreements to obtain or provide toxicology services
- Develop a compliance plan for same
- Identify and self-regulate questionable marketing practices which may rise to the level of legal and ethical breach of protocol