Whats the OIG looking for?
According to the fraud alert, the OIG would study three areas of a rental agreement to determine whether it is suspect. Appropriateness of rental agreements. According to the OIG, “The threshold inquiry when examining rental payments is whether payment for rent is appropriate at all.” For instance, payments of “rent” for space that you traditionally have provided for free or for a nominal charge as an accommodation for the benefit of your patients, such as consignment closets for durable medical equipment, may be disguised kickbacks. In general, payments for rent of consignment closets in physicians’ offices are suspect. Rental amounts. According to the OIG, rental amounts should be at “fair market value,” should be fixed in advance and should not take into account, either directly or indirectly, the volume or value of referrals or other business generated between you and the lessee. “Fair market value” means the rental payments should not exceed the amount paid for comparable property
