read the entire OIG memo. HDL does not violate any of the items. FMV is a non issue cuz avg of reimb on draws is about equal to their doc fees. Pays per patient, not per test. Does not place draw people inside office. Does not carve out Fed patients. HDL pays the practice, not the doc. Not sure how HDL would be made accountable if another lab placed an employee there to draw, and physician collected fee. Would that really stand up in court? So HDL is supposed to monitor what another labs employee does?
It's all smoke. HDL will live on just like all the other businesses follow the law to the letter. Loopholes are made to be jumped through.