Thompson Coburn partner John Howard and associate Christine Moser recently collaborated with ECG Management Consultants on an article examining the growing regulatory scrutiny surrounding medical director arrangements. The article explores how health systems have long relied on these arrangements to compensate physicians for administrative and leadership responsibilities, including service line development, clinical oversight, strategic planning, and quality improvement efforts. When structured appropriately, medical directorships can help health systems achieve operational goals while enhancing patient care.
The authors note that recent enforcement actions have placed these arrangements under a sharper regulatory lens. “However, recent federal enforcement actions signal increased scrutiny by the United States Department of Justice (DOJ) and the Department of Health and Human Services Office of Inspector General (HHS-OIG) of medical director arrangements,” they wrote. They explain that regulators are increasingly focused on ensuring organizations maintain adequate documentation of services performed and time worked, while also demonstrating fair market value compensation and commercial reasonableness.
Drawing on recent enforcement trends, the article outlines key compliance considerations for healthcare organizations and offers practical guidance for structuring, documenting, and monitoring medical director arrangements to mitigate risk.
Read the full article here.
