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Non-MD consultant

anonymous

Guest
I have a situation where a prominent national laboratory is paying an office manager with no clinical expertise to be a “consultant”. In return, her clinic refers all testing to said lab. To my knowledge, there are no other “non-MD” consultants and she doesn’t see to be doing any actual consulting work.

This seems like a very cut and dry case of a stark law violation. I know speakers bureaus and KOL’s are heavily utilized but this is way outside that realm. Thanks
 




Hi,

It seems odd. But without knowing more details it’s difficult to determine if this arrangement violates either the Stark Law or the Anti-Kickback Statute. Keep in mind that there are several safe harbors that allow for financial relationships. Do you know if this office manager has a consulting contract with specified terms?
 




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