Question -
We are in the process of contracting with a third-party hospital with Healthcare professionals (mostly physicians) on staff being paid a salary. The amount payable by our company goes directly to the hospital, and the HCPs involved will just get their regular salary as employees of the hospital.
Are we required to report any spend amounts for those Hospital employed HCP's?
Answer -
The payment would only be reportable to the hospital, assuming they are on the teaching hospital list. The HCPs are receiving their salary and no amount given to them as part of that salary could be attributed to the payment your organization paid to the hospital.
If we were to attribute a portion to each HCP, theoretically every payment to a hospital would have to be looked at in this way as each hospital has HCPs salaried. I would also advise you to add a quick note to your assumptions document stating your opinion and how you choose to move forward.
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