Compliance Officers' Forum

Consider the following scenario/arrangement:

A hospital-based clinic leases a group of physicians from a medical practice to staff its clinic.  The hospital provides everything typically included in the Practice Expense RVU – space, clinical and administrative staff, medical and office equipment, etc.  It has been proposed that the physician group bill the "global service"  under POS 11, Physician Office, and remit part of its collections back to the hospital instead of typical leasing agreements for space, staff, etc.  It has been opined that this remit may satisfy the PE portion.  Have any of you heard of this or have experience with this?  

Consider the following scenario/arrangement:

A hospital-based clinic leases a group of physicians from a medical practice to staff its clinic.  The hospital provides everything typically included in the Practice Expense RVU – space, clinical and administrative staff, medical and office equipment, etc.  It has been proposed that the physician group bill the "global service"  under POS 11, Physician Office, and remit part of its collections back to the hospital instead of typical leasing agreements for space, staff, etc.  It has been opined that this remit may satisfy the PE portion.  Have any of you heard of this or have experience with this?  

Should you and @Lisa Martin chat, would I be able to join you?I am really struggling with this and would appreciate the conversation. 

Consider the following scenario/arrangement:

A hospital-based clinic leases a group of physicians from a medical practice to staff its clinic.  The hospital provides everything typically included in the Practice Expense RVU – space, clinical and administrative staff, medical and office equipment, etc.  It has been proposed that the physician group bill the "global service"  under POS 11, Physician Office, and remit part of its collections back to the hospital instead of typical leasing agreements for space, staff, etc.  It has been opined that this remit may satisfy the PE portion.  Have any of you heard of this or have experience with this?  

Consider the following scenario/arrangement:

A hospital-based clinic leases a group of physicians from a medical practice to staff its clinic.  The hospital provides everything typically included in the Practice Expense RVU – space, clinical and administrative staff, medical and office equipment, etc.  It has been proposed that the physician group bill the "global service"  under POS 11, Physician Office, and remit part of its collections back to the hospital instead of typical leasing agreements for space, staff, etc.  It has been opined that this remit may satisfy the PE portion.  Have any of you heard of this or have experience with this?