STARK BASIC TRAINING - The American Health Lawyers Association
STARK BASIC TRAINING - The American Health Lawyers Association
STARK BASIC TRAINING - The American Health Lawyers Association
Create successful ePaper yourself
Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.
ICA EXCEPTION<br />
• Compensation must be FMV not taking into<br />
account referrals or other business generated<br />
• Does not look to aggregate compensation<br />
• Apply special compensation rules at<br />
411.354(d)(2),(3) regarding per unit comp<br />
• Other requirements (e.g., in writing)<br />
41<br />
SPECIAL RULES ON<br />
COMPENSATION<br />
• Unit-based comp does not TIA “v/v of referrals” if<br />
per unit payment is FMV and does not vary during<br />
the term in a manner that TIA referrals of DHS.<br />
• Example of varying: $10/item for first 100 items;<br />
$8/item thereafter<br />
• Unit-based comp does not TIA “OBG btw the<br />
parties” if FMV and does not vary during the term<br />
in manner that TIA referrals or OBG, including<br />
private pay business<br />
42<br />
21
Change language