Potential Violation of Anti-Kickback Statutes???

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drmedicineman

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My jurisdiction is: Delaware

My question is in regards to the Anti-kickback statute. I represent a medical practice of chiropractors in Delaware. They desire to setup a medical staffing arrangement in which they will provide chiropractic services to patients inside the offices of an MD/DO practice at an agreed upon hourly rate. The chiropractic practice will bill all services under their own EIN and deposit the funds into an escrow account. At the end of the month, the total number of chiropractic hours provided will be tallied and the chiropractic practice will be paid directly from the funds held in escrow. The remaining will belong to the MD/DO practice. I have researched this and have found that the Stark Law does not apply to chiropractic medicine as it is not listed as a designated health service. However, I'm not sure if the arrangement may fall into one of the Anti-kickback safe harbors. Please advise.:confused:
 
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