How to Stay Out of Jail: The Latest On Management Fees and The Company Model of Anesthesia and Other Specialty Services


There's a metastasizing trend among surgery centers and their surgeon owners: establishing entities to coordinate the provision of anesthesia services to their patients – and to capture the profits.

That same model has been expanded to capture the income from other specialists as well.

Other referral sources have used other methods: Fees for services, fees for space, fees for billing – all commonly referred to as management fees.

These are the so-called "company model" and management fee structures put into place to skirt what can't be accomplished outright: receiving a share of fees in return for referrals.

But do these models work? Should the participants in these deals be jubilant or prepare to be jailed? That’s the $25,000 fine plus five years in jail plus exclusion from Medicare and Medicaid question.

The Office of Inspector General has opined on these questions and it may be time for those in company model and management fee deals to prepare for a trip to Club Fed.

After viewing this recording of an ALG Webinar, you'll emerge with:

  • An understanding of the basics of the federal antikickback statute
  • Familiarity with several variants of the so-called "company model" structure
  • An understanding of how "management fees" can be disguised kickbacks
  • Knowledge of the OIG's Special Fraud Alert on Joint Venture Arrangements and Special Advisory Bulletin on Contractual Joint Ventures
  • Understanding of the analysis of the OIG's Advisory Opinion 12-06 on the company model and management fee arrangements


You'll gain awareness of the issues involved in analyzing a proposed company model, management fee or other joint venture.  This is practical and actionable information for your group’s immediate application.

Click here now to purchase How to Stay Out of Jail: The Latest On Management Fees and The Company Model of Anesthesia and Other Specialty Services.


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