This information bulletin presents legal issues that can arise in the context of hospital-funded recruitment and retention payment arrangements and suggests ways to appropriately address those issues. The document identifies conditions that must be met to assure such arrangements do not raise potential violations under the Stark Law, the Anti-kickback Law, and Internal Revenue Service standards for tax-exempt organizations.
Important NACHC Library Content Note: This technical assistance resource was developed prior to the August 2017 release of the Health Center Compliance Manual by the Health Resources and Services Administration’s (HRSA) Bureau of Primary Health Care (BPHC). The BPHC Compliance Manual, issued August 2017, indicates where PINS, PALs and other program guidance are now superseded or subsumed by the BPHC Compliance Manual.
This project was supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS).