What should a compliance professional's NEXT step be if they identify payments to physicians for medical directorships without written contracts?

In a situation where payments to physicians for medical directorships are identified without written contracts, the most appropriate next step would involve determining if any Medicare payments were received. This step is critical because if Medicare funds are involved, the implications for compliance can be more significant.

If Medicare payments were indeed received, it may trigger additional legal and regulatory scrutiny. Medicare has strict guidelines regarding relationships between healthcare providers and physicians, especially concerning fair market value and self-referral laws. Establishing whether Medicare payments were involved helps to assess the exposure to potential legal issues linked to improper payment arrangements and compliance violations.

Understanding the presence of Medicare payments will also inform further actions, including whether voluntary self-disclosure may be necessary, as compliance with Medicare regulations is essential. This foundational assessment is crucial for driving compliance actions and mitigating risk effectively.