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7. Physician Recruitment

Remuneration provided by a hospital:

  1. To induce a new practitioner who has been practicing in her specialty for less than a year to induce such practitioner to locate in a HPSA.

  2. To induce an established practitioner to relocate her primary place of practice to an HPSA, provided at least 75% of the revenues of the new practice come from patients who were not seen by the physician at her former practice.

Note that this safe harbor limits the time period for recruitment payments to three years, but does not prescribe the nature of the payments (i.e., whether they include income guarantees, moving expenses, etc.), leaving that determination to negotiation by the parties.

Anti-Kickback Safe Harbor

Sources: 42 C.F.R. § 1001.952(n)

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