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CONFIDENTIALThe ASC Safe Harbors: An Overview and KeyConsiderations for EnforcementNorth Carolina Bar Association Health Law Section2010 Annual MeetingBart [email protected](704) 373-8923 CONFIDENTIALI. Overview of Anti-Kickback StatuteII. Overview of ASC Safe HarborsIII. Monitoring and Enforcement ConsiderationsIV. Special ConsiderationsV. Questions CONFIDENTIALWhy is this important?•More aggressive government enforcement•Increased enforcement in surgery centers (for both good and bad motives)•Safe Harbor compliance is often tied to physician redemptions•Frequent disputes•Applicability outside ASC context CONFIDENTIALI.Overview of Anti-Kickback Statute•Summary: Prohibits the knowing and willful solicitation, receipt, offer or payment of any remuneration (including any kickback, bribe or rebate) directlyor indirectly, overtlyor covertly, in cash or in kind, in return for or to induce the referral, arrangement or recommendation of Medicare or Medicaid business.•Simplyput, i...