Non-MD consultant

Discussion in 'Ask a Whistleblower Attorney' started by anonymous, Apr 11, 2019 at 2:01 PM.

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  1. anonymous

    anonymous Guest

    I have a situation where a prominent national laboratory is paying an office manager with no clinical expertise to be a “consultant”. In return, her clinic refers all testing to said lab. To my knowledge, there are no other “non-MD” consultants and she doesn’t see to be doing any actual consulting work.

    This seems like a very cut and dry case of a stark law violation. I know speakers bureaus and KOL’s are heavily utilized but this is way outside that realm. Thanks
     

  2. WBI Law Firm

    WBI Law Firm New Member

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    Hi,

    It seems odd. But without knowing more details it’s difficult to determine if this arrangement violates either the Stark Law or the Anti-Kickback Statute. Keep in mind that there are several safe harbors that allow for financial relationships. Do you know if this office manager has a consulting contract with specified terms?