I was reading the Whidbey Island Hospital District's Stark and Anti-Kickback civil monetary settlement with the government and it's a classic example of sloppiness. The Office of Inspector General contends the hospital had more than 100 violations stemming from its physician contracts and arrangements. Here are just a few of them and let this be a lesson to all physicians – even though the hospital is the one who got in to trouble, there are rumblings the government is eventually going to go after all participants in alleged compliance abuses:
1. Missing signatures on call-coverage contracts;
2. No contracts for medical staff leadership arrangements;
3. Office space lease that had a contract term for less than a year;
4. Missing signatures on hospitalist arrangements;
5. A housing allowance with no contract;
6. An equipment loan without a written agreement; and
7. Personal services agreement with term of less than a year.