Hello, everyone, and thank you for joining me in the Medical Practice Operations Business Fundamentals 101. This is Module 4, and today we will be discussing some legal aspects of healthcare delivery to get you up to speed. So while practice management generally, whether you're on the ambulatory side or in the hospital side, while practice management generally speaking is really business management, the differentiator that makes healthcare a little more prickly is that there are a lot of landmines that need to be navigated in the healthcare space. Mainly those are with regard to sharing of patient information, paying kickbacks for referrals, things of that nature. When the government is involved in those types of things, the driving force really is to make sure consumers have choice and that things like referrals are not occurring so that someone can make money off of them, just putting it in very low-key terms. So again, thank you for joining Module 4. If you're not doing this sequentially, this module will stand for the most part on its own, but I do suggest that you go through all the other different modules in the series. So again, as per the norm, nothing to disclose, and most importantly, this presentation is not legal advice. It should not be construed as legal advice. Any decisions involving legal aspects of healthcare should be vetted via qualified legal counsel. So what I'm telling you is very top-level legal stuff that I am not an attorney, but I know and have dealt with historically, and I know when to call counsel in. So again, this is for informational, educational purposes. As with all of the other modules and the upcoming modules, one size never fits all. These decisions in the legal space are predicated on and driven by your demographics and your situation, and we'll find out or you will learn a little bit more about that as we go through this. So a little bit about WIFLI. If you have not done any of the prior modules, WIFLI is a 105-year-old accounting firm based in the Midwest, and we do accounting tax audit related work in all of the verticals on the screen right now that are, that is to say, healthcare, agribusiness, construction, real estate, auto dealerships, financial institutions, etc. And in each of those where we do accounting, audit, tax, etc., we also have consulting arms. And as such, in the healthcare space, I run the National Physician Enterprise. So I deal with, by and large, outpatient-related healthcare work. In the 32-33 years I've been in professional life, half of that has been running private practices, and the other half of that has been in consulting-slash-advisory work. And so in terms of the clients that I deal with, what we call the healthcare delivery platform, I deal with academic medical centers, rural health systems, rural hospitals, rural clinics, FQHCs, federally qualified health clinics. I've done tribal work. I've done de novo surgery center. I've done surgery center improvements. I've done private practice work, etc. I am specialty agnostic, care delivery agnostic, and have seen much of what happens in healthcare, although every day I feel like I do learn more. That's what's kind of interesting and exciting about healthcare. So 10 modules in this practice management 101 series. The nomenclature is a little bit wonky because we do have two very large and bulky modules that were split into two pieces with finance and then with revenue cycle. So the nomenclature is eight modules, but we actually have 10 when all is said and done. And the goal, which I don't know that I've said in any of the other taped modules, is really to give you a facile topical macro understanding of some of the moving parts within the healthcare delivery space. These are things that aren't provided in healthcare training for clinicians, and the hope is to give you a little better sense, get you higher up on the curve vis-a-vis nuts and bolts of healthcare practice operations. So the learning objectives in today's legal module, non-exhaustive list of legal pitfalls and issues in the healthcare system. I'm going to paint really a picture of four or five of the largest pillars related to legal within the healthcare space. And if I can think of a couple other ones as we go, because I don't think I covered compensation on this, but we'll cover those. And as I said in the preamble, healthcare is business management, but with different legal exposure vis-a-vis delivery of care. And while some of the legal pieces to my way of thinking, and this is just one man's opinion, some of it is a little bit of overkill, like HIPAA, in my opinion, could have been managed a lot differently. It became this, well, basically became its own business, but some of it is logical and intuitive. And I think some of the legal pieces that have evolved from the United States Congress are really are sort of the swinging of the pendulum to overcorrect. So if you're like flying a plane in rough weather, and then you decide you're just going to land the plane while you're doing 300 miles an hour, that's problematic. So maybe that's not a good analogy, but the bottom line is many of these laws evolve and they overcorrect for something that otherwise, let's look at it this way. It's a shotgun approach when you could have used a single bullet. My other caution to you is trust in legal experts, not your buddy who just graduated from law school. As with any specialization, there is nuance and medical law, legal aspects have some particular nuances relative to the delivery of care. I think it's just that simple. So as with consultants, like if you're going to hire a consultant to help you with your medical practice, I wouldn't hire someone just because he runs the widget factory down the road. Healthcare delivery has a lot of layers to it. And it's worthwhile spending the money to invest in people who are eminently qualified, have background in what it is you're trying to accomplish, whether that's in consulting for operations, or the legal piece or the healthcare IT piece. So our non-exhaustive list, here are the things we're going to cover today. Some of them, again, bridge between just practice, business, management 101, and some are very much the result of congressional input. We'll move on, but we're going to touch a little bit on HR, HIPAA, exposure in some deals that happen, fair market value exposure, commercial reasonableness. We're going to touch a little bit on Stark and then antitrust, anti-kickback, talk a little bit of fraud and abuse and how those definitionally, at least in terms of, or in the eyes of the government are different things altogether. And then we'll talk mitigation of these risks. And then we'll get a little bit into a key TAM, which is a whole different animal for practitioners to be aware of. So HR, this is probably the simplest thing vis-a-vis healthcare practice management, because it is human resources 101. It's ensuring that you've got a good HR legal person. If you've got a small practice, you're probably going to contract with a legal person. In this regard, generally speaking, my sense is you could have a generalist who understands human resources, national, so federally mandated and regulated laws and regulations, as well as someone within the state who understands the goings on with issues that might be peculiar to your state. So just like any small business or any business, these are the things that really drive how you are managing, or at least the parameters with which you manage your business and how you deal with your folks. So there are hiring laws. Most of them are going to be state or federal. Generally speaking, they won't be broken down to the local level. There are laws with regard to how you fire folks. If you just get rid of a segment of 60-year-olds, candidly, they would probably have at least a potential action based on their ages. So you have to be really careful with how you've documented what is going on and what your reasoning was to terminate an employee. You have to be cognizant of age, race, ethnicity, if they're on the, or if they have a disability and are listed in the Americans with Disabilities Act, et cetera, et cetera, et cetera. So in lieu of someone, if you're in a small clinic, in lieu of trying to manage all of that yourself, you engage a firm that can help you to do that and mitigate risk. So we spoke in one of the other modules about operations and how you manage folks, right? And you try to have no surprises. You're very clear in what your expectation is for the jobs. And where possible, you have quantifiable, measurable tools so that you can have a valuable discussion with your employees about how they are succeeding or where they are struggling so that you can manage them to improve, or if need be, manage them out the door. You have to keep employees safe. There are a whole slew of OSHA-related laws, especially in healthcare when you're dealing with, let's call ambulatory outpatient spaces. If you're engaged with or doing procedures at a surgery center, there is on-the-job risk and there's mitigation things that need to be put in place. So that's where the HR piece would really cross over into the medical spaces where you deal with OSHA, specifically healthcare-related pieces, and it would behoove you to deal with a group that is into, handles mitigation on the surgery center side. A lot of that comes with your certification work and your credentialing work, but it is where certainly some of those protective measures cross from HR into the medical realm. Family Medical Leave Act, workers' comp, any on-the-job injuries like needle sticks, all of those other pieces are items that need to be managed by a qualified human resources professional. Your HR person might also deal with payroll taxes, profit sharing 401k, etc., or shopping for health insurance for the clinic. These things need to, again, be managed by professionals, specifically in a private practice, because there are some tax issues with deploying the wrong 401k profit sharing plan, etc., and there are also benefits to shareholders with regard to how their plan is structured. So that really requires someone intimately familiar with the 401k profit sharing investment tools within a clinic setting. HIPAA. To my way of thinking, HIPAA was overreached by the government. Basically, the genesis, and I'm going to be parsing this and paraphrasing, but really what happened is there were a few bad actors that were selling patient information to help improve sales for others. I believe the genesis of this was in the pharma industry, and really a few bad actors forced the government to deploy reams of pages of what to do and how to protect information. So PHIs protected patient information generally means you can't talk about patient's medical record with anyone but the patient. However, a patient can select a designee who you can share information with, and that would be in the paperwork when they're going through their new patient visit or their update of their information at front desk, which is, you know, let my wife be my designee. She can get all my medical records information. Also, and again, this is generally speaking, you can share healthcare-related or care delivery-related information with other clinicians so that you can co-manage care and billing with insurance companies and third-party vendors and any employers who have a self-directed plan. The goal behind that, obviously, is if you're an internal medicine doctor and you wanted to refer to an otolaryngologist, you shouldn't have to get a whole new HIPAA waiver every time you want to send a patient over. So that was the pushback that came out in the early 2000s, and the federal government saw clearly that that was going to be an impediment to care delivery. Vendors who are outside vendors to the care delivery process but might have exposure or access to PHI must sign a business associates agreement where they basically say they understand they've got protected information. They are going to protect it and manage it and not allow for, just to say, out-migration of particular data elements. So certain aspects of transmission and sharing of data elements that might be tied to or ID-ed back to a patient need to be protected or redacted. So if you're doing work with an outside vendor and it's on, for instance, a certain disease state, you may blind or redact the patient's name and account number or the patient's name and use the last six on a patient's internal account number, something like that, so that you could access back internally, but the outside vendor can't see those data elements. And again, you can see where this gets sideways very quickly in a subtle reminder or not-so-subtle reminder. I am not a healthcare attorney, and this kind of setup, this kind of discussion needs to occur with a qualified healthcare attorney who handles and is well invested in HIPAA and all the rules and regs around HIPAA. Cybersecurity concerns and considerations. You have probably heard at this point, and if you haven't, I'm not sure where you've been, but ransomware concerns and other cybersecurity violations where, so ransomware, a hacker will go in and lock down a health system's EMR and then demand ransomware, a lot of times via Bitcoin or some other difficult-to-track currency exchange or something akin to it, and then they will give a key or free up the lockdown service. You can see the problem there, aside from the operational aspects of not having access to your EMR or EHR, but also the operational aspects of not being able to, or of the, excuse me, of the hacker having access to PHI. So groups, and this really, again, broadly speaking, but anyone in the healthcare space, you have to have policies in place to delineate what to do when there's a healthcare breach of PHI, to find the patient's rights so they understand what those are, train staff and HIPAA rules and regs, probably do a refresh on occasion, and then update them on anything that arises in the interim and protect patient information. It's better to err on the side of protection than not. So deal exposure, again, not an attorney, just going to give you a sense of some of the things that are out there relative to mergers and acquisitions related healthcare deals. So the Federal Trade Commission, for all intents and purposes, has oversight, and they can tank deals, or let me rephrase that, maybe a different word would be, they can ruin deals as anti-competitive, and here's how. If you have two groups coming together, whether hospitals or medical practices, they can't come together to dominate the market. That is to say, if you have 1,000 physicians in your market, and then 995 physicians are in this one aggregated group, that becomes a problem with the Federal Trade Commission, and they can begin governmental action to break up those groups. And the reason being, if you think this through, I alluded to sort of an absurd example earlier, if you're together, you have all the leverage to negotiate your contracts. And that, basically, you can, first of all, it's anti-competitive, and you can have these exorbitant rates in theory, because there's no other competition in the area. And in our example, the 995 docs or whatever in a group with five docs outside the group, those five docs, you can say, well, they could handle the business. They can't. They just can't handle that overload. So it's anti-competitive. Again, it's like Delta, United, and all the other airlines saying, hey, we're going to charge $10,000 for a round trip from Atlanta to San Francisco. Obviously, that creates problems. And again, that's a supply and demand issue. I get it. But the example is, they can artificially inflate rates. And that's where the federal government could look at these and say, yeah, that's not going to work in this market. As with everything we've discussed, it is market driven, regional driven. This is not necessarily a national thing, although I have been privy to, well, this did become a market deal. I was privy to a consulting company buying a very large medical practice that would have given them a large majority of the providers in the area. And the Federal Trade Commission said the deal could go through provided in this certain western state that they carved out these physicians in this city and sold them elsewhere. And so that's what happened. A case summary. I will read this, actually. The Federal Trade Commission authorized administrative complaint and a suit in federal court to block the proposed merger of two large health systems in Utah, alleging the deal would lead to higher prices, as I discussed. This was not the case I was contemplating, but this is the net result. Excuse me. And that it could lead also to lower quality care. So you may have thoughts going into this or may not even contemplate it. These are some of the aspects. And this deal exposure happens in other business verticals, but it also does happen in health care. Fair market value. Fair market value contemplates that a deal is constructed on the quote unquote fair value of an entity. And as I alluded to earlier, the goal is to ensure that deals don't impact referral rates or direction of referrals. Right. So if I'm an internal medicine guy and I'm referring to Hospital X and then they give me, as you recall, we discussed in an earlier module, having service line director privileges at a health system, which has to be an FMV construct if you're not employed. So let's change this model. We'll say, all right, I'm a cardiologist. I'm referring to Hospital X and I give them, I don't know, 10 interventions a month just because that's kind of where my volume is. I'm comfortable there. Well, Hospital Y comes up and says, I'm going to give you a million dollars a year to be my service line director. And then all of a sudden, all of my stents and all of my EP procedures and everything else are flowing to Hospital Y. That obviously impacts referrals. And did it impact referrals because I think Hospital Y has better care? The government would come in and make the argument, whether it's right or wrong, that Hospital Y is paying you to send those referrals over to Hospital Y. You can see how this gets a little murky and how this can stick out. Again, this is a value in arm's length transactions consistent with a general market value. If I was an informed entity with as much deal knowledge, market knowledge as possible, and the entities pay the value that's requested. Everyone would say, well, what's a Ferrari worth? Well, Ferrari is worth what the market will pay for it. It's not when a Ferrari rolls off the line and it's sold at a quarter of a million dollars and it's worth that. It's worth that because Ferrari has sent their cars out. The consumer or the market has said, we will pay $250,000 to $500,000 for your cars. That's what the value is. That gets a little prickly, but there is data out there on some of these deals. For instance, if Clinic X is worth $5 million as a going entity. If I'm going into a medical practice, it's got five doctors and it's worth $5 million a year, and a hospital wants to pay me 10 million, why would they do that? What's the value of the health system in paying two times the day-to-day rate? Well, that's again where the government will say, why are you doing that? Why would the hospital do it? Why would any prudent person who's well-informed do that? That's where a fair market value assessment comes into play. Fair market value is not only in deals, but also in compensation. We alluded to this a little earlier as well in one of our prior modules, is that if a health system is hiring a physician, taking them from outside practice, what does that look like? Let's say Dr. Schmo, if you look at the right-hand side of the screen, he generates $50 per work hour view, and he's working 7,800 hour views. You recall from our earlier modules what a work hour view is and how those values are built. A comp plan may be built out by the health system where they've got guardrails set up, where the doctor will have a median compensation for his specialty might be $500,000. Then the 75th percentile might be $750,000, where the expectation is you're going to be putting out somewhere on the order of 10,000 hour views in the median production. You can see how that starts to work. Our current physician, Dr. Schmo, is at the 50th percentile based at these numbers. He's about the median, half or above, half or below. Let's say that Dr. Schmo gets into the hospital, still making the hour views, generating 16,000, he's up to 800,000. He's falling well beyond the 75th percentile. He's at the 80th percentile. But you can also make an argument, well, his production is well above the 75th percentile. The bottom line there is maybe that's okay because maybe he's the only orthopod in the middle of nowhere in Arizona or New Mexico, but maybe the health system brought him on board. See, the thing that messes this model up is if you are paying him $800,000 to generate the 7,800 work hour views, then that becomes weird, right? Because that gets back to why are you paying him so much higher? Again, for instance, if you have a cardiologist making $500,000 a year, why would you pay him a million? What's the logic in that? Now, as I said, outliers can exist. They just need to be vetted very carefully. You need to be able to substantiate an argument as to why an outlier might exist. So a good example, I know an orthopod who made a very good living. This orthopod was a well-known trainer for a big league sports franchise. And so there is value, there is cachet with associating one's name to being the lead orthopod for this franchise. So you can make a legitimate argument that this physician is worth more than, and I don't mean to say this disrespectfully, than an orthopod who's just doing these every day. Again, no disrespect. This too is not something that I would do internally and say, hey, we could pay this guy a million five because he works with NFL Franchise X. That's not the way this goes. So it requires really an outside force to come in, look at the data and make that argument or refute your argument. Here's another area where fair market value comes into play. So fair market value leasing from a medical office building. Let's say a hospital owns an office building. I am an ophthalmologist and I don't work for the hospital. They don't employ me. So I have my own company and I want to rent there because they have a surgery center. I can get in and do cases. They will give me block time. So I want to sublease or lease out. And let's say I'm only going to go into that office one day a month. And so rent for the location, let's call it 5,000 feet of office. The fair market value of that office space is $120,000 a year for that 5,000 square foot space or $24 a foot. And so actually I messed up my example here, forgive me, but let's change it really quick. And we'll say it's an ophthalmologist who wants to rent out, sublease out some of his or her space. So you have an optometrist who wants to rent or has the rent of the scenario at the right. So he's got a 5,000 foot location. He wants to carve out a little bit for the ophthalmologist. Let's say he wants $1,000 a month to rent that space out. Well, doing the simple math, you can see the monthly, the daily rent for this is $227. If this physician, and I'm sorry, I hope I'm making this clear because I got a little sideways on the beginning of my example. But the daily rent for this place based on work days is $227 a day. You cannot charge the ophthalmologist $1,000 a month. And here's why. The ophthalmologist is in a position to benefit from the optometrist, right? So if I'm the optometrist, he's going to, he or she's going to pay me $1,000 a month to rent. That's almost three times, that's almost four times more than the fair market value. So I'm making money. That's taking $1,000 off my monthly rental payment, reducing it right out of the gate to $4,000 a month. And oh, by the way, maybe all of a sudden my cataract referrals or my glaucoma checks or whatever else are going to this ophthalmologist. So you can see the government's logic behind making sure the deals are fair because they don't want to incent possible changes in referral patterns based on finances or financial benefit. I hope that was clear. My apologies. Commercial reasonableness kind of touches up with the fair market value piece. So from the Centers for Medicare and Medicaid Services, CMS, commercial reasonableness is a sensible and prudent business arrangement from the perspective of the particular parties involved, even in the absence of referral. So if there's no referral gain or loss, but it makes sense to do the deal, then that's commercially reasonable. And it means that the arrangement furthers a legitimate business purpose to both parties, and the arrangement is sensible considering the characteristics of the parties, including their size, scope, et cetera. I am not an expert in commercial reasonableness, but the bottom line to it, generally speaking, is that would you do the deal, all things being equal, right? And that is, again, it's a fair market deal kind of thing, and a lot of times these two go together. It doesn't make sense to do the deal for an informed buyer, informed seller, willing buyer, willing seller. Physician self-referral law, the Stark Law, this is, again, my sense is a little bit of overreach, coming from really a handful of bad actors who sullied or mucked up the waters for the other folks who really weren't sending themselves referrals, or had business interests. Here's kind of how this goes. Physicians must disclose ownership in businesses they refer to. So if you're an orthopedic surgeon and you have a surgery center, if you're going to refer to that surgery center, you need to let patients know that you have an interest in that so they can make a different decision if they want to. It's not to say that they will, but you are obligated. And, again, this is for the patient to go, all right, I understand Dr. X is going to make money on my surgery at the surgery center. Ditto with an ophthalmologist referring you to a surgery center that he's a part owner of. They need to disclose that so you at least make an informed purchase decision. So per the American Society of Anesthesiology, and you can find this anywhere, this comes from Medicare, driven, again, by Medicare Medicaid, it's a violation of civil laws prohibiting self-referral, specifically referral by a physician to a Medicare or Medicaid patient to an entity that they provide designated health services in. Won't get a DHS right now. You can look those up or talk to your fair market value person to discuss what those are in detail. Also, it applies to immediate family members. So I can't have my daughter as a straw man managing partner of a surgery center that I own, again, because we, me and the family make all the money out of that surgery center. So broadly put, and, again, generalizing here, broadly puts prohibitions on referring patients to a health care company which a doctor has a financial interest. There are financial risks, civil penalties, 15,000 per service that you know or should have known violated the law. Treble, so three times improper payment received from Medicare and possible exclusion from Medicare and Medicaid. So if you're in a Medicare Medicaid heavy population base, more specifically Medicare, and you're, say, an orthopod or an ophthalmologist in Florida, that will be painful for your business entity, and those can be exclusion for up to five years or more. Antitrust, anti-kickback, you can't kick dollars back to referrals for health care business. So in other words, again, we'll use our ophthalmologist and optometrist model. I say to the optometrist down the road, for every patient you send me for cataracts, I'm going to give you $1,000, or for every $1,000 I generate, I'm going to give you $250. And I will tell you, I think I mentioned this in one of my earlier modules, I did hear of a group that was compensating or wanted to compensate their advanced practice professionals based on the number of EKGs that they ordered and billed. That is on its face bad or otherwise put yucky. There is criminal statute. There can be jail time. You got to make sure that deals with any outside entities align generally with accepted practices and don't smell of you paying a referral or referrals. Same thing with pharma companies. They can't pay you. And this is why, you know, back in the day, pharmaceutical companies used to give you box seats at hockey games, etc., etc. Now they've been minimized, best I recall, to bringing launches in and doing CME with clinicians. Historically, there were payments made for physicians who wrote scripts, and the government caught on to that and put the kibosh on it. Possible penalties for violating AKS include violations up to $25,000, up to five years in jail, and exclusion. And that, again, is a quote from American Society of Anesthesiology. But I'm sure if you dug into the CMS website, you would find that as well. Maybe even Department of Justice. Fraud and abuse. I have said prior, I worked fraud and abuse when I finished my undergrad 800 years ago. What we did in that space at the time was the government defined fraud as intentionally billing for services you didn't perform, or intentionally, inaccurately billing. So a couple of those could be a patient was supposed to come in today. They didn't come in today, but you billed an office visit anyway. And that's really prickly because the patient's going to get an EOB and they can look at their calendar and say, well, wait a minute, I wasn't there. But in any event, that is fraud because you were intentionally defrauding the government. Upcoding, if you're doing a level, and we talked about this relative to comp in module 2A or 3A, I think. Upcoding, if you're doing work for a level two and you're billing a level five, you will stick out to the government after a certain amount of time. Now, if they come to you and they say, why are you billing all these level fives? You can say, you know, look at all these comorbidities and I am in the sickest town in the United States and all this stuff. If you've documented it, it's legitimately provable. The government will say, OK. However, the onus is on you to prove that you are billing the appropriate level of care, seeing the patient, spending quality patient facing time with the clinicians, etc. Abuse, as they termed it in the early 90s, that's accidental billing. It doesn't obviate you from paying Medicare back, but it's, you know, I made a mistake. I billed incorrectly. You need to pay back the fees. So basically, and I have been involved in this back in the day when I ran clinics, I went to a clinic that was doing some diagnostic procedures and they were billing them erroneously. And we went through counsel and said, hey, we billed these wrong. Here's what we found. Here's how we fixed it. Here's what we think we owe the federal government. We went through counsel to the federal government. They said, sounds good. Send us a check and don't send any more. And we did. So I'm finding a qualified attorney going through that attorney who can protect, you know, attorney client privilege and who understands they can work on your behalf. But having said that, you will minimally have to pay back any defined overpayment. Key Tam is interesting. And when I was putting this presentation together, kind of slipped my mind. And then I went to some literature that I had published a while back and I thought, I need to put this out there. And here's what Key Tam means. So Latin, it means who sues on behalf of the king as well as for himself. And how that applies in healthcare is if you have an employee who knows that you are committing a fraudulent act or committing some sort of sin. And in my way of thinking, it should be fraud, willing fraud versus accidental use. Nonetheless, employees are incented to report you to the federal government. So reporters can be financially rewarded for what they report out to the government. So if they report, Susie Q says, hey, Dr. X is billing for surgeries he doesn't do. Or he's making an incision on a big toe and then billing minor surgical procedures on feet. That's a problem. And they can report that. And then the federal government, if they're interested, can come back and say, oh, OK, I see. And they find that to be true. Let's say that's ten million dollars. The reporter, your staff member, would get in a million and a half to three million dollars of that settlement. So there is an incentive. A, you should be doing the right thing anyway. But there is an incentive for employees to report out. I don't know that a lot of them understand that. But that is lurking out there. And if you get disgruntled folks and you're running afoul of the law and doing so with knowledge and willingly, you could have a very serious issue. And I have seen cases. I can't remember one in particular ran into the eight figures to the reporter. You're over ten million dollars. That person just won the lottery because the provider providers in question were doing things they should not have done. So basically, what would happen to in terms of process, the government, if they like the case, they'll accept it on behalf of the reporter and then they will handle all the rigors of bringing the case to court. Findings could lead to exclusion from Medicare for several years. And again, we talk about what what that means to you. If you're have a if you have a large Medicare demographic, not only that, you could end up in stripes and or a orange jumpsuit for a period of time. The government can look at the case on its merits and decide not to pursue. That is their choice. But word to the wise, this just gives you more thought relative to your exposure. Risk mitigation avenues to protecting yourself, your practice. And again, this is for private practice. It's for health systems. Need to understand everyone is exposed to all of these things we talked about today. But if you're employed by a health system and they start paying folks based on referrals or whatever else, that's not on you as long as you're not a party to what that looks like, the mechanics of it. Always get qualified legal counsel. There are subspecialists to handle these pieces that we've gone through today. Use your common sense. If it smells bad, it probably is. There is no free lunch, et cetera, et cetera. You really need to noodle this around. Follow the money. Just get a common sense approach. Who's going to win? Who's going to lose on this? Have internal compliance plans in place with ongoing education with some frequency and ensure compliance and reporting when you need to report. If something goes south or someone in your office in, report it through the proper channels, but do so through your qualified legal counsel. They provide a buffer and arm's length, and they have attorney-client privileges with you, as best I know. Again, not an attorney. So that is my very broad overview for the legal aspects of healthcare delivery. Again, we have not covered everything. All of these topics are big, and they all have their subspecialties within the healthcare legal realm, and they all have micro components to them. So the goal here, as with all modules, is to just give you a broader sense of the goings-on within the practice management healthcare delivery space. So as with the other modules, we will have a Module 8, or as I've presented with the other modules, we'll have a Module 8. It will be a live WebEx on May 10th, 7 p.m. Eastern Time. We urge you to submit any questions or comments you have. We'd like to get a bunch of those fleshed out and ready to go in a WebEx format or another PowerPoint presentation format. And the goal, too, is to be able to manage some of the questions on the fly. But if there are questions that are out there, we would love to get them loaded ahead of time so that we can discuss them and then manage some other questions while we're on the move. I am always available for follow-up or questions ahead of time. If you cannot make it to the presentation on May 10th at 4 o'clock Pacific Time, the presentation will be recorded for on-demand viewing at a later date. Any questions you have, you can submit those to the fine folks at AOA. Submit the questions to physicianservicesatosteopathic.org. And I will look forward to seeing those questions. I thank you once again for your time and for spending some of your day with me. I know that you all are very busy, and that makes me more appreciative. So thank you for your time. I look forward to the next presentation, Module 5, in the near future. Thank you.

healthcare management

patient privacy

HIPAA

Stark Law

anti-kickback

risk management

qui tam

compliance plans