What type of arrangement might lead to OIG identifying an "outlier" for non-compliance?

Large, inconsistent payments to physicians can draw scrutiny from the Office of Inspector General (OIG) because they may raise red flags regarding potential violations of federal healthcare laws, such as the Anti-Kickback Statute. When payments to physicians vary greatly without a clear and justifiable reason, it suggests that the arrangement could be designed to induce referrals for services, resulting in a conflict of interest. Such inconsistent financial relationships might be interpreted as an attempt to manipulate or circumvent regulations designed to ensure that healthcare decisions are made based on the best interest of patients rather than financial incentives.

In contrast, routine audits of claims are typically a proactive approach to ensuring compliance and would not inherently signal non-compliance. Providing patient education is a standard practice that promotes health literacy and is not likely to create compliance concerns. Conducting employee performance reviews is a managerial function that, while important for organizational effectiveness, does not directly relate to potential regulatory violations concerning payments to healthcare providers. Thus, the focus on inconsistent payments serves as a significant indicator for the OIG in identifying possible non-compliance with healthcare regulations.