The following Model Agreement between a testing lab and a referring physician was created by Savannah, GA, lab compliance attorney Adam Walters and structured to minimize kickback liability risks to each party in
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It’s not uncommon for labs to place a phlebotomist in a physician’s office to collect and process samples for testing. While not strictly illegal, this practice raises bright red flags under kickback laws. So, it’s imperative to carefully vet your in-office phlebotomist arrangements to ensure they don’t cross any kickback lines.
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From - G2 Compliance Advisor Editor's Note: Two months ago, we talked about paying referring physicians a fee for collecting and processing blood, urine, tissue and…