Skip to content

menu

Open Legal Blog Archive logo
HomeAboutBlogsFAQsSubmit

HHS Advisory Opinion Approves Profit-Based Bonus Plan for Bona Fide Physician Employees

By Gretchen Heinze Townshend, Helen Suh, Michelle Claverol, Timothy Fry, Kimberly J. Kannensohn, Kristen McDermott Woodrum, Natalie Galdos & Kristen H. Chang on October 30, 2023

On Oct. 13, the U.S. Department of Health and Human Services Office of Inspector General issued an advisory opinion approving a physician practice’s proposal to pay bonuses to each of its employed physicians based on net profits derived from the facility fee generated by procedures the physician performed at the practice’s ambulatory surgery center.

Read on for analysis of this opinion and how the proposed arrangement avoids implicating the federal Anti-Kickback Statute.

  • Posted in:
    Administrative, Corporate & Commercial
  • Blog:
    The FCA Insider
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

Open Legal Blog Archive, Inc. logo
Seattle, Washington
Copyright © 2026, Open Legal Blog Archive, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo