What happens when 19 partners sign your conflict of interest disclosure and one refuses? If your governance documents don’t have an answer, your practice is exposed.

Healthcare attorney Neal Goldstein breaks down how private physician groups should approach conflict of interest policies without turning into policing organizations. Designed for physician owners, practice executives, and medical group boards, this breakdown covers the exact financial relationships that threaten your compliance and bottom line, and how to handle partner non-compliance before it fractures your group.

What you will learn:
● Why private physician practices do not need hospital-style financial disclosures, and how Stark II and tax-exempt rules drive hospital compliance.
● The difference between policing every partner’s passive outside investments and requiring self-reported material disclosures.
● Why partner ownership in a competing ambulatory surgery center is a massive business risk to your group’s strategic capital.
● How outside financial relationships with designated health service (DHS) providers like imaging centers, labs, and physical therapy trigger Stark Law exposure.
● Why medical director or management agreements with local hospitals must be disclosed as direct competitive threats.
● How the “selective enforcement trap” turns an unenforced compliance policy into a retaliation or hostile work environment lawsuit.
● How to structure confidential reporting channels and tiered disclosures so partners protect their privacy while board leaders fulfill their fiduciary duties.
● How to separate disciplinary actions from partnership remedies when a productive physician refuses to act like a partner.

Timestamps:
00:00:21: Conflicts of Interest and Governance in Physician Groups
00:02:29: Do Private Practices Need Hospital-Style Financial Disclosures?
00:04:17: How Stark Law and Anti-Kickback Statutes Impact Group Practices
00:10:18: The 4 Financial Conflicts Every Physician Group Must Track
00:14:05: Managing Disclosed Conflicts vs. Prohibiting Outside Investments
00:15:00: What to Do When a Physician Partner Refuses to Disclose
00:17:19: Avoiding the Selective Enforcement Trap in Practice Governance
00:18:48: Practical Frameworks for Confidential Reporting and Partner Remedies

About the Host:
Neal Goldstein is a healthcare corporate attorney and the host of Group Practice, where he helps physician owners, medical group executives, and healthcare leaders navigate the business and legal realities of independent medicine. He specializes in physician group governance, mergers and acquisitions, regulatory compliance, and strategic practice growth.

Website: https://www.pfs-law.com/
Website: https://www.goldsteingrouppractice.com/
Website: https://nealtgoldstein.com/
LinkedIn: https://www.linkedin.com/in/neal-t-goldstein-841aa652/

New episodes every Tuesday, subscribe so you never miss one.
Spotify | Apple Podcasts | YouTube

Disclaimer: The information provided in this video is for educational and informational purposes only and does not constitute formal legal advice or establish an attorney-client relationship.

#PhysicianPractice #HealthcareCompliance #StarkLaw #MedicalGroupManagement #HealthcareLaw #PhysicianLeadership #GroupPractice #PrivatePracticeMedicine #HealthcareGovernance #PhysicianContracts

That lucrative new specialty care network contract might actually be an illegal kickback scheme in disguise.
Specialty care networks are rapidly expanding in commercial healthcare by using bundled payments to control costs. In this solo breakdown, healthcare attorney Neil Goldstein examines how physician groups and healthcare executives can distinguish legitimate value-based networks from disguised pay-for-referral schemes that violate the Federal Anti-Kickback Statute.

What you will learn:
● How legitimate specialty care networks mirror Medicare bundled payment models to lower commercial healthcare costs for employers and TPAs.
● Why paying a physician participation fee to join a network is a major Anti-Kickback Statute warning sign when the network should be funded by payers or shared savings.
● The difference between acceptable network marketing and illegal commission-based patient generation under federal law and state fee-splitting statutes.
● Why carving out Medicare and Medicaid patients provides false comfort unless the network operates solely in a legitimate state-regulated niche like workers’ compensation.
● How termination without cause clauses can be manipulated to adjust fees based on referral volume unless a strict one-year sit-out provision is included in the contract.
● Why a compliant specialty network must assume genuine financial downside risk on bundled payments rather than acting purely as a patient sales broker.
● The operational markers of a legitimate network, including defined clinical care pathways, data analytics, and active care management.

Timestamps:
00:00:00: Anti-Kickback Statute risks in specialty care networks
00:02:17: How legitimate specialty networks use bundled payments
00:04:00: True care management vs disguised referral schemes
00:06:45: Warning sign 1: Physician participation fees
00:09:05: Warning sign 2: Marketing as the primary network service
00:10:31: Warning sign 3: The false comfort of federal carve-outs
00:13:00: Warning sign 4: Termination clauses without a one-year sit-out
00:15:09: Warning sign 5: Networks taking zero financial downside risk
00:17:11: Warning sign 6: Lack of meaningful clinical pathways and data services

Neal Goldstein is an experienced healthcare attorney, advisor, and host of Group Practice, dedicated to helping physician leaders navigate complex legal, financial, and governance structures. He counsels medical groups on sustainable growth, partner alignment, and sound operational decision-making. His strategic guidance ensures independent practices stay profitable and resilient in rapidly consolidating markets.

Website: https://www.pfs-law.com/
Website: https://www.goldsteingrouppractice.com/
Website: https://nealtgoldstein.com/
LinkedIn: https://www.linkedin.com/in/neal-t-goldstein-841aa652/

New episodes every Tuesday, subscribe so you never miss one.
Spotify | Apple Podcasts | YouTube

This content is for informational and educational purposes only and does not constitute formal legal or financial advice.

#HealthcareLaw #MedicalPractice #AntiKickbackStatute #HealthcareCompliance #PhysicianGroup #BundledPayments #ValueBasedCare #MedicalLaw #SpecialtyCareNetwork #OIGCompliance

Think your new healthcare joint venture is legally protected? Strip away the corporate shell and the OIG might see a disguised illegal kickback.

In this episode of Group Practice, healthcare attorney Neal Goldstein breaks down the legal dangers of contractual joint ventures under the federal Anti-Kickback Statute (AKS). Using the 2003 OIG Special Advisory Bulletin and real-world OIG Advisory Opinion 21-18, this breakdown shows practice owners, healthcare executives, and compliance counsel exactly how seemingly standard business expansions trigger federal fraud scrutiny.

What you will learn:
● The core purpose test of the federal Anti-Kickback Statute and why simple business deals fail it.
● The 5 specific indicia the OIG uses to identify suspect contractual joint ventures.
● Why NewCo shell entities fail to shield owners when turnkey services eliminate bona fide business risk.
● A deep dive into OIG Advisory Opinion 21-18 involving physical therapy management and skilled nursing facilities.
● Why an arrangement does not need to hit all five suspicious criteria to receive an unfavorable OIG ruling.
● How disguising management fee revenue splits functions as remuneration for patient referrals.
● The critical practitioner gut check: balancing profitability against genuine patient-first care.

Timestamps:
00:00 — Anti-Kickback Statute and OIG Safe Harbors Explained
01:43 — The 2003 Contractual Joint Venture Advisory Bulletin
04:12 — Five Indicia of Suspect Joint Venture Arrangements
07:27 — OIG Advisory Opinion 21-18: The SNF and Therapy Deal
11:42 — How the NewCo Management Structure Was Built
14:45 — Why Turnkey Operations Lack Bona Fide Business Risk
16:36 — Peeling Back Corporate Camouflage on Disguised Kickbacks
18:37 — Respect for the Patient: The Practitioner Gut Check

Neal Goldstein is an experienced healthcare attorney, advisor, and host of Group Practice, dedicated to helping physician leaders navigate complex legal, financial, and governance structures. He counsels medical groups on sustainable growth, partner alignment, and sound operational decision-making. His strategic guidance ensures independent practices stay profitable and resilient in rapidly consolidating markets.

Website: https://www.pfs-law.com/
Website: https://www.goldsteingrouppractice.com/
Website: https://nealtgoldstein.com/
LinkedIn: https://www.linkedin.com/in/neal-t-goldstein-841aa652/

New episodes every Tuesday, subscribe so you never miss one.
Spotify | Apple Podcasts | YouTube

This content is for informational and educational purposes only and does not constitute formal legal or financial advice.

#healthcarelaw #healthcareregulations #antikickbackstatute #oigcompliance #healthcarecompliance #jointventures #skillednursingfacility #medicarefraud #healthlawyer #grouppractice