• A pharmaceutical representative ("Rep") lives next door to an orthopedic surgeon ("Surgeon") who is on staff at Hospital ("Hospital") and also is a member of a private practice that leases office space in a building owned by Hospital.
• While attending a football tailgate, Surgeon introduces Hospital CEO ("CEO") to the Rep
• The Rep recommends a physician friend who will be moving to the community to establish a new practice.
• Surgeon offers for the Rep and the CEO to join him and to invite the relocating physician to go fishing at Surgeon's lake house the following weekend.

CEO suggests that they can use the Hospital's patient transport van for that purpose.

1. Identify any potential issues that may arise with regard to the anti-kickback statute and regulations.
2. Discuss how those issues may be addressed in the context of the statute and regulations and potential protections under one or more safe harbors.
3. Discuss the statute's impact on the business of health care.

Please post your answer first and then comment on postings by at least one of your classmates.

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