Tom, that's not the issue. Payment from the federal government is not intrinsically dirty or evil. The issue of this thread is that of simple threat management; protecting ourselves from fines from security audits, charges of fraud for simple coding errors, and other very direct threats. If your assessment is that it is in you best interest to accept reimbursement from certain sources, and in return accept that you will need to implement programs such as JamesNT has outlined to mitigate the associated risks, then well and good. Our decision is that it is not worth it for us, and going down that path will only get worse and worse, like picking peaches for 2 1/2 cents a box. And my post is meant to remind folks that doing so is a choice. If you make it, you deserve that it should be a conscious and informed decision, rather like deciding whether to have a prostatectomy for early prostate cancer.


David Grauman MD
Department of Medicine
Commonwealth Health Center
Saipan, Northern Mariana Islands