Hospital Assistance for Relocation of Non-Physician Practitioners to Physician Practice

- Member in good standing at the Hospital
- The physician practices solely in the specialties of primary care or mental health services, unless approved by the AGC
- No prior relocation assistance received except if
    - The NPP replaced a NPP who terminated their employment or arrangement within the past three years
    - The total payment did not exceed two consecutive years’ worth from start of employment or contractor arrangement of the NPP being replaced
    - The AGC approves assistance where the physician was provided relocation assistance within the past two years
- NPP relocation as part of a physician relocation arrangement and the relocating Physician has not received payment under this policy within the past three years 
- Physician is not eligible for assistance to relocate a NPP who is a member of his or her immediate family

- Agreement Form
  - Approved template for assistance agreement available in CAM
  - Signed and dated by Hospital, Physician and NPP after approval in eCATS

- Limitations 
  - Tenet may not restrict physician or NPP from  
    - Staff privileges at non-Tenet hospital or facility
    - Patient referrals or services at non-Tenet hospital or facility
    - Business development for non-Tenet hospital or facility

- Representations
  - Services the NPP provides to patients of the Physician’s practice are Primary Care or mental health care services
  - Physician and NPP will treat all Federal health care program patients in a nondiscriminatory manner
 
- Flow Down Requirements 
  - Tenet’s Compliance Program
  - Tenet’s Code of Conduct
  - Tenet’s policies and procedures (Anti-Kickback and Stark laws)
  - Certification by parties (Anti-Kickback and/or Stark laws)
  - Any required training under Tenet’s Compliance Program

- NPP compensation arrangement is with the Physician
    - NPP is an employee or contractor, no third party intermediary is allowed
    - Compensation is not to exceed 50% of the total compensation paid to the NPP
    - Compensation includes signing bonus, benefits, relocation payments by physician to the NPP of the first two consecutive years between the NPP and Physician
    - Benefits are limited to health insurance, paid leave, relocation costs, other routine non-cash benefits
- Payment does not include additional incremental practice expenses attributed to the NPP
- Documentation
    - Copy of the written agreement between the Physician and NPP
    - Other documentation of compensation and other benefits provided to the NPP
    - Records of payments provided by the Hospital to the Physician
    - Records of payments provided by the Physician to the NPP
    - Payments records must be kept for at least six years and available to the Hospital and U.S. Department of Health and Human Services Secretary

- NPP will not have practiced in the geographic area being served by the Hospital within one year of the start the compensation arrangement with the Physician
- NPP will not have been employed or engaged to provide patient care services by a Physician or organization with a medical practice site located in the geographic area being served by the Hospital
- NPP ownership or investment interest in the Physician group practice is not allowed
- Patient care service performed by the NPP shall not be restricted in the geographic area being served by the Hospital

- Time spent on patient care services by NPP
    - Documentation such as time cards, appointment schedules, or personal diaries
    - Alternative tracking can be used if it is reasonable, fixed in advance of services being done, consistently done, verifiable and documented
- Data used to calculate percentage of time spent by NPP 

- Hospital submits the electronic contract approval term sheet with:
  - Request for Agreement form
  - NPP’s current resume/CV
  - Criminal background check 
  - Employment or independent contractor agreement between the physician and the NPP or written description of the terms of the arrangement that has been prepared by the physician 
  - FMV supporting documentation for compensation to the NPP by the physician
  - Search results showing no exclusions, suspensions or debarments of the NPP and Physician:
      - U.S. General Services Administration’s System for Awards Management
      - Office of Inspector General of the Department of Health and Human Services List of Excluded Individuals/Entities
      - Any applicable state healthcare exclusion list 

- Monthly statement of actual costs and benefits to be paid to NPP provided by physician
- Payment approved by CFO after receipt of necessary documentation
- Payment made after all approvals and executed agreement is in eCATS by CFO