Research Paper

You are a new and the first compliance officer at a hospital system comprised of four hospitals and seven physician offices. You have a non-profit status. You were asked to draft a memo and corresponding slide deck for a board of directors meeting. They want to know the following:

1. What are your duties as a compliance officer? See: http://www.hcca-info.org/

2. What is the Stark Law? Who does the law pertain to exactly? How does it differ from the Anti-Kickback Statute? See: http://oig.hhs.gov/compliance/provider-compliancetraining/files/StarkandAKSChartHandout508.pdf

3. How many exceptions are there to the Stark law? Focus on one exception pertaining to compensation arrangements. Define it and provide a rationale for it. Give an example of a fact pattern that will legally trigger the exception.

4. Which federal agencies provide information and support regarding the Stark Law?

5. What is a corporate integrity agreement? Find one that mentions either a Stark or AntiKickback violation. Which provider was cited? What was their penalty?

6. Can the board of directors be held liable for such violations? What do they need to know to stay away from any exposure? Where can they learn more about their potential legal liability?

7. Create a list of sources for future use: the CFR section, a law review article, links to federal websites, stakeholder associations for hospitals, one hospital website that describes their compliance program, a white paper or journal article and a news article.

This paper should be single spaced. No more than six pages in length. Use legal citations and/or APA citations as appropriate. Use headings to organize your paper. Work with your assigned partner. This paper will constitute 30% of your overall class grade. For the corresponding presentation you can use PPT or any other tool available to you.