Bethany J. Hills, a Member of the Firm in the Health Care and Life Sciences practice, in the firm’s New York office, was quoted in Part B News, in “Protect Practice Reimbursements as 100% IRS Liens on Physician Payments Begin,” by Roy Edroso. (Read the full version – subscription required.)
Following is an excerpt:
It also may be dangerous to fire an employee because of debt. Instead, you should ask the prospect to affirm in contract that he or she has no debt obligations that would pose a danger to the firm, says Hills.
“You would want a certification process to determine the provider has no current IRS debt,” says Hills. “Accuracy then becomes a trigger for termination — they’re not terminated because of the withholding but because of their failure to notify.”
You’ll want to revisit this affirmation annually, says Hills. “When we do [Medicare] exclusion checking, there’s often a lag between the exclusion and when it shows up in the database,” she says. “The same thing happens with tax liens: There could be a significant lag between the debt and the lien. So you should have a credentialing request each year.”