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You are the compliance officer at ABC Hospital. The Hospital's chief operating officer reaches out to you. She describes the above scenario to you. She
You are the compliance officer at ABC Hospital. The Hospital's chief operating officer reaches out to you. She describes the above scenario to you. She says the Hospital has needed cardiology medical director for some time, and the lack of cardiology medical director has probably resulted in lower quality patient care and, on a few occasions, patient harm. Therefore, the hospital would like to contract with the cardiologist. She asks your advice on how to proceed. Questions The memo should: Identify any Stark and/or Anti-Kickback issues presented by the scenario; Explain your reasoning for why these may be issues; Ask counsel to answer specific questions about the scenario
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