RCM Compliance for Stark Law and Anti-Kickback in Radiology Services

  • High-Risk Specialty: Radiology’s costs, referral frequency, and financial ties make it prone to Stark and Anti-Kickback violations.
  • Contract Hygiene: All agreements must be written, FMV-backed, commercially reasonable, and referral-independent.
  • Referral Monitoring: Track volumes, spikes, and patterns; investigate and document anomalies.
  • Safe Payments: Use fixed fees or hourly rates; avoid volume-linked bonuses or per-study payments.
  • Disclosures & Training: Maintain updated ownership disclosures and scenario-based staff training with clear escalation paths.
  • Governance & Metrics: Implement dashboards, audits, and approval workflows; track compliance scorecards and resolve risks promptly.

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