Navigating the complexities of physician contract compliance is a critical challenge for healthcare organizations. Our Physician Contract Compliance Review Audit Report is designed to help you evaluate and enhance your physician contracting and payment processes. This audit framework focuses on ensuring alignment with federal regulations such as Stark I, Stark II and the Federal Anti-Kickback Statute—laws that govern the design, documentation and execution of financial arrangements with physicians. The report provides actionable insights through a detailed review of active physician contracts and associated payments. It identifies key compliance risks, such as missing documentation, incomplete contracts, inconsistent payment practices, and nonadherence to regulatory requirements like one-year term lengths or fair market value provisions.

The tool also highlights gaps in processes, such as contracts commencing before full execution, and offers recommendations to mitigate these risks. The tool also outlines best practices for maintaining compliance, including the incorporation of termination clauses, fair market value documentation, and monitoring tools for noncash compensation. With appendices detailing specific test results, this report equips organizations with the knowledge to address deficiencies and strengthen their internal controls. This indispensable resource is ideal for legal, finance and compliance teams seeking to safeguard their organization against regulatory penalties and reputational risks.

Recommendations include:

• A process should be developed to ensure that all contractual elements of a contract are complete prior to contract execution.
• A process should be developed to ensure, to the extent possible, that the contract is properly executed by all appropriate parties prior to the commencement 
  of services.
• All physician contracts should contain defined requirements for payment documentation. In addition, a process should be developed to ensure that all documentation is submitted and reviewed timely.
• All physician lease agreements should contain clauses to cap month-to-month extensions at six months.