ESSENT HEALTHCARE, INC.
Section:
Corporate Compliance
Effective Date: 11/01/05
Subject: Employment of Physicians
Revision Date:
03/25/08
Policy #: CC-23
Review Date:
03/25/08
Responsible Party: VP Corporate Compliance
Revision #:
2
CC-23-Employment of Physicians
Page 1 of 5
Scope:
This policy applies to all Essent facilities.
Purpose:
The purpose of this policy is to provide direction as to Essent’s process for entering into
employment relationships with Referral Sources.
Policy:
It is the policy of Essent Healthcare, Inc. to fully comply with all Federal, State and Local
laws and regulations with regards to the employment of physicians or other referral
sources. The procedures outlines below must be followed in all situations involving the
employment of a physician or any other referral source (including immediate family
members).
Written Agreements
All employment arrangements with Referral Sources must be in writing.
All such written employment agreements must comply with this policy.
Compliance with State and Federal Fraud & Abuse Laws
All physician employment arrangements must comply with all applicable federal and state
laws, including but without limitation, Stark II and the Anti-Kickback statute, both as
amended from time to time.
All such employment arrangements must be undertaken without regard to the value or
volume of referrals and must not include any intention to induce referrals.
Compliance with the Standard of Fair Market Value and Commercial Reasonableness
The amounts paid to Referral Sources under an employment agreement shall be no greater
than the fair market value for the services provided, shall not be based upon the value or
volume of referrals or any referral relationship between the parties, and shall be
commercially reasonable even if no referrals were made to the employer by the Referral
Source.
ESSENT HEALTHCARE, INC.
Section:
Corporate Compliance
Effec