In the recent case — U.S. ex. rel. Godsholl v. Covenant Healthcare – it was alleged that medical directorship roles were awarded as perks and described as “improper appointments.” Apparently, the smoking gun for this improper financial relationship was the fact that there was no oversight or record keeping to account for the medical directorship work justifying the additional compensation paid to referring physicians. It’s a good idea to have not only an FMV opinion for medical directorship compensation but also a commercial reasonableness smell test to verify if the position is necessary or redundant. Not to mention the absolute necessity for regular and accurate record-keeping.
