Amy Joseph shares advice on:
- How to navigate fraud & abuse laws
- Key questions to help your company structure a compensation arrangement
Amy: There are a number of fraud and abuse laws out there. And at their core, what they say is, you're prohibited from providing financial value to a physician in order to generate referrals.
There’s sound policy behind it. We don't want physicians making decisions based on personal financial gain, as opposed to what's best for the patient in that moment.
And so because of that, you do have to be careful with structuring, but there can be a path forward. It really depends on what the physician is doing to get that equity. Are they providing a meaningful contribution? Is the equity that they're getting fair market value? Are they treated like any other investor?
So there are questions that we walk through. And we also need to understand the facts and which laws apply. So in short, it does depend, but if you're thoughtful about it and you work through it from the get-go, there can be a path forward.
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