Structuring Physician Compensation Arrangements

Meeting Legal Requirements, Ensuring FMV and Commercial Reasonableness, Lessons from Recent Enforcement, Mitigating Fraud and Abuse Risks

Recording of a 90-minute CLE webinar with Q&A

Conducted on Tuesday, May 9, 2017
Recorded event now available

This CLE webinar will provide guidance to healthcare counsel on physician compensation arrangements. The panel will examine the legal requirements for such arrangements as well as the many potential risks. The panel will discuss the implications for Stark, Anti-Kickback and False Claims Act compliance and offer best practices for structuring compensation arrangements.


Physician compensation arrangements are increasingly complex and present liability risks. The Office of Inspector General (OIG)’s fraud alert, “Physician Compensation Arrangements May Result in Significant Liability,” released in 2015, put physicians on notice that compensation arrangements must be for bona fide services and at a fair market value (FMV).

Compensation arrangements must also comply with the Stark law and False Claims Act (FCA), among others. Any attempt to compensate a physician for past or future referrals may violate the Anti-Kickback Statute (AKS) and expose the parties to penalties and sanctions, including exclusion from Medicare and other federal healthcare programs.

Similarly, risks for fraud in compensation arrangements are rife; key risk areas include reporting, accounting practices, descriptions of work performed, and more. Healthcare counsel must seek to minimize liability exposure while ensuring compliance when structuring physician compensation arrangements.

Listen as our authoritative panel of healthcare attorneys examines the legal requirements for physician compensation arrangements and addresses commercial reasonableness and FMV issues. The panel will also discuss lessons that can be learned from recent enforcement actions and will offer best practices for structuring and auditing physician compensation arrangements.


  1. Legal requirements for physician compensation arrangements
    1. Stark Law
    2. AKS
    3. FCA
    4. IRS Section 501(c)(3)
    5. Civil Monetary Penalty Law (CMP)
  2. Commercial reasonableness, FMV and not taking into account
    1. Compensation stacking
    2. Physician losses
  3. Enforcement
  4. Best practices for structuring and auditing physician compensation arrangements


The panel will review these and other key issues:

  • What steps can healthcare advisers take to ensure regulatory compliance when valuing physician compensation?
  • What are the implications for compliance with the Stark Law, the AKS, and other laws and regulations?
  • What lessons can healthcare counsel take away from recent enforcement actions?


Anna M. Grizzle, Member
Bass Berry & Sims, Nashville, Tenn.

Ms. Grizzle focuses her practice on representing healthcare providers and companies in operational and compliance matters, investigations, and litigation. She works with clients to develop policies in anticipation of government and commercial payor claims audits and represents clients in responding to claims audits and in the appeals of audit results.

Tizgel K.S. High, Vice President, Associate General Counsel, Legal
LifePoint Health, Brentwood, Tenn.


Albert D. (Chip) Hutzler, Partner
HealthCare Appraisers, Delray Beach, Fla.

Mr. Hutzler focuses on fair market value analysis of hospital arrangements with physicians for clients nationwide, including on-call arrangements, medical directorships, employment arrangements and physician recruitment arrangements. Prior to joining HealthCare Appraisers, he worked for a law firm representing healthcare clients, including a large health system, in various physician contracting arrangements, healthcare law and investment matters.


CLE On-Demand - Streaming Video

Includes recorded streaming video of full program plus PDF handouts.

On-demand is the only recorded format recognized for CLE credits in DE, IN, KS, LA, MS, NC, OH, OK, SC, TN, VA, WI.

AK, AZ, CA, CO, CT, DE, FL, GA, HI, IA, ID, IL, IN*, KS, KY, LA, ME, MN, MO, MT, NC, ND, NH**, NJ, NM, NV, NY, OH*, OK, OR, PA, SC, TN, TX, UT, VA, VT, WA, WI, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)

*Only available for attorneys admitted for more than two years. For OH CLE credits, only programs recorded within the current calendar year are eligible - contact the CLE department for verification.

**NH attendees must self-determine if a program is eligible for credit and self-report their attendance.

CLE On-Demand Video $297.00

How does this work?

Recorded Event

Includes full event recording plus handouts.

Strafford is an approved provider and self-study CLE credit is available in most states.

AK, AZ, CA, CO, CT, FL, GA, HI, IA, ID, IL, KY, ME, MN, MO, MT, ND, NJ, NM, NY, OR, PA, TN, TX, UT, VT, WA, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)

Strafford will process CLE credit for one person on each recording.

Additional copies of a recording can be purchased at a discount. Please call Strafford Customer Service toll-free at 1-800-926-7926 ext 10 or email to place your order.

Recorded Webinar Download $297.00

How does this work?

Recorded Audio Download (MP3) $297.00

How does this work?


Strafford webinars offer several options for participation: online viewing of speaker-controlled PowerPoint presentations with audio via computer speakers or via phone; or audio only via telephone (download speaker handouts prior to the program).  Please note that our webinars do not feature videos of the presenters.

Program Materials

Requires Adobe Reader 8 or later. Download Acrobat FREE.

Program Materials

Requires Adobe Reader 8 or later. Download Acrobat FREE.

or call 1-800-926-7926

CLE Credits

Many states grant CLE credits for on-demand streaming audio programs and recorded events. Our programs are pre-approved in many states. Refer to our state CLE map for state-specific information.

or call 1-800-926-7926

Customer Reviews

I enjoyed the quality of the presentations and the information presented.

Cassandra Pullen

Fresenius Medical Care North America

I liked the use of current court cases.

Robert Cundiff

Northwestern Memorial Hopsital

The seminar tackled a difficult issue that we need to understand better.

Evan Smith


I appreciated the speakers' insight and was pleasantly surprised how helpful I found the presentation.

Heidi Brasher

McAfee & Taft

I liked that the slides automatically moved along with the presentation of each speaker.

Ann Marie Henderson

Staten Island University Hospital

or call 1-800-926-7926

Health Law Advisory Board

Lowell C. Brown


Arent Fox

Jennifer L. Evans



Ryan S. Johnson


Fredrikson & Byron

Gina M. Kastel


Faegre Baker Daniels

Karen S. Lovitch


Mintz, Levin, Cohn, Ferris, Glovsky and Popeo

David A. Manko


Proskauer Rose

John J. Miles

Senior Counsel

Baker Donelson

C. Elizabeth O'Keeffe


Wyatt, Tarrant & Combs

J. Peter Rich


McDermott Will & Emery

Donald H. Romano

Of Counsel

Foley & Lardner

Judith A. Waltz


Foley & Lardner

John R. Washlick


Buchanan Ingersoll & Rooney

Jesse A. Witten


Drinker Biddle & Reath

or call 1-800-926-7926

Our Guarantee

Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.