Structuring Physician Compensation Arrangements

Ensuring FMV and Commercial Reasonableness, Mitigating Fraud and Abuse Risks, Lessons From Recent Enforcement

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

Conducted on Tuesday, March 12, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will guide healthcare counsel on physician compensation arrangements. The panel will examine the legal requirements and the many potential risks. The panel will discuss the implications for Stark, Anti-Kickback and False Claims Act (FCA) 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 fair market value (FMV).

Compensation arrangements must also comply with the Stark law and 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
    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?


Grizzle, Anna
Anna M. Grizzle

Bass Berry & Sims

Ms. Grizzle focuses her practice on representing healthcare providers and companies in operational and compliance...  |  Read More

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

Ms. High is the vice president, associate general counsel for physician services at Lifepoint Health. Lifepoint is a...  |  Read More

Hutzler, Albert
Albert D. (Chip) Hutzler

HealthCare Appraisers

Mr. Hutzler focuses on fair market value analysis of hospital arrangements with physicians for clients nationwide,...  |  Read More

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