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WMLM1407 - CME/CMLE - LMU 28 (Fundamentals) Financ ...
WMLM1407 - Pre-Reading Assignment 2
WMLM1407 - Pre-Reading Assignment 2
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Pdf Summary
Hospitals are increasingly providing outreach clinical laboratory services as a response to consolidation in the independent clinical laboratory sector. This shift allows hospitals to reduce costs and expand services through core laboratories, joint ventures, or outpatient department growth. However, legal issues arise with IRS pronouncements impacting not-for-profit institutions' joint ventures with for-profit labs and federal fraud and abuse laws affecting hospital-lab arrangements. The distinction between outpatient and nonpatient status under Medicare is crucial, with implications for billing and encounters at hospitals. Nonpatient services have billing and MSP implications. HIPAA requirements vary based on direct or indirect treatment relationships. Hospitals establishing independent clinical laboratories must obtain separate Medicare provider numbers and comply with CLIA certification. Segregating costs between hospitals and independent labs is essential to avoid improper inducements under the Antikickback Statute. Considerations for hospitals entering joint ventures with for-profit labs include tax-exempt status, community benefit, and unrelated business income tax. Legal counsel should review agreements to ensure compliance with regulations, especially concerning referrals and financial aspects. Collaboration with accountants and legal advisors is vital in navigating the complexities of evolving legal issues in the clinical laboratory industry.
Keywords
outreach clinical laboratory services
hospital-lab arrangements
IRS pronouncements
federal fraud and abuse laws
Medicare billing
HIPAA requirements
independent clinical laboratories
CLIA certification
Antikickback Statute
tax-exempt status
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