On the 13th of September 2023, Oliver Street Dermatology Management LLC, a renown dermatology practice manager, reached a settlement with the U.S. Attorney’s Office for the Northern District of Texas. According to the Public Report, Oliver Street agreed to a payment of $8.892 million to the United States to resolve self-reported allegations of violating multiple laws.
The alleged statutory infringements included the violation of the Physician Self-Referral Law (commonly known as the Stark Law), the Anti-Kickback Statute (AKS), and the False Claims Act (FCA). These allegations resulted from the company’s recent series of acquisitions. Within a span of five years, Oliver Street had acquired several dermatology practices, actions which the U.S authorities deemed to be illegitimate under the mentioned Federal laws.
The stark law is a provision that prohibits physicians from referring patients to receive “designated health services” payable by Medicare or Medicaid from entities in which the physician, or an immediate family member, has an ownership/investment interest or with which he or she has a compensation arrangement. The Anti-Kickback Statute is a criminal statute that prohibits the exchange (or offer to exchange), of anything of value, in an effort to induce (or reward) the referral of federal health care program business. Alongside these, the False Claims Act is a federal law that imposes liability on persons and companies (typically federal contractors) who defraud governmental programs.
Although the settlement was considerable, it resolved the potential looming litigation that was facing Oliver Street Dermatology Management LLC. It also sent out a strong message about compliance to the industry as a whole.