FON: THE BUSINESS OF INTEGRATIVE HEALTH & MEDICINE

By Michael H. Cohen, JD Is it fee-splitting to hire another medical doctor, chiropractor, acupuncturist, or other health care practitioner in your office and give them a “cut” of patient revenues? Fee-splitting, “Stark,” self-referral, and anti-kickback issues concern many health care practitioners who seek legal counsel from our law firm. Here’s one typical scenario: You’re an acupuncturist and you want to hire a second acupuncturist as an independent contractor. The patient pays

By  Michael H. Cohen, JD telemedicine laws: who operates the sites and provides content? are the visits to the site considered clinical encounters, or merely visits to receive general information and education? is personalized healthcare advice being given? will the physician be obligated to have medical licensure in the state of the patient, as well as the home state or originating site? is a restricted telemedicine license available? antikickback and

By Michael H. Cohen, JD Many physicians, chiropractors, acupuncturists, and other healthcare practitioners want to know whether they are fee-splitting when they rent a room hourly from a medical practice or other healthcare facility or practitioner. The answer, of course, depends on the arrangement, including whether other aspects of it raise fee-splitting, Stark, or anti-kickback considerations. Let’s focus for now just on the hourly rental. The problem with this is that