Overview
The PDP model was developed with the assistance of prominent healthcare attorneys to meet and exceed current regulatory guidance regarding physician joint ventures. We have obtained formal opinions and supporting white papers from well known national healthcare law firms. We are confident that our model represents the regulatory “best practice” with respect to structural features and operational safeguards identified by the Office of Inspector General (OIG). This confidence is reflected in the approval of our model by leading law firms representing the many major hospitals, manufacturers and physician groups whom we support and with whom we do business.
The PDP Model
PDP’s model reflects the state of the art with respect to each of the characteristics identified by the OIG, and incorporates additional unique features further addressing traditional OIG concerns with physician-owned entities. The PDP Model is not a distributor or affiliate of any manufacturer. Thus, it does not incorporate any manufacturer or distributor as an owner or partner, and is not the sort of joint venture with which the OIG has been concerned. The OIG’s existing guidance relates to ventures between Medicare providers and physicians in a position to refer business to them. Our complete independence from manufacturers and their distributors eliminates any appearance that physician ownership opportunities represent an inducement from them for referrals, the OIG’s primary concern with such ventures. Our model’s insulation of surgeons from financial interactions with manufacturers and hospitals similarly addresses traditional OIG concerns. We welcome the opportunity to discuss our model with you or your counsel at your convenience.