On February 25, ASA formally urged the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) to issue a special fraud alert regarding the "company model" and to modify existing safe harbors to prevent referring physicians from profiting from their referrals for anesthesia services.
ASA filed these comments in response to the December 27, 2013 HHS-OIG solicitation for new potential safe harbors, modification to existing safe harbors, and special fraud alerts. Under the company model, referring physicians, who typically also own the facility where surgical procedures are performed, form a separate anesthesia company in order to share in anesthesia revenue.
Over the past two years the HHS-OIG has issued two advisory opinions on the company model. Advisory Opinion No. 12-06, issued in June 2012 and Advisory Opinion No. 13-15 issued last November.
ASA has serious concerns about the impact of the company model, and variations of that arrangement, on anesthesiologists, the patients they serve, and the integrity and fiscal soundness of Federal health care programs. ASA has consistently advocated against company model arrangements.
Review ASA’s formal comments to HHS-OIG Inspector General Levinson dated February 25, 2014.
Review the HHS-OIG Notice.
Review ASA’s formal comments to HHS-OIG Inspector General Levinson dated February 26, 2013.
Review ASA's formal communication to Inspector General Levinson dated February 27, 2012.
Review the updated Company Model FAQ.
Watch the Special Company Model Webinar Presentation.