QuIC

The Quality Implant Coalition (QuIC) is a coalition of manufacturers of medical devices that is concerned with the potential for harm to patients, payers, and the general health care system that inevitably arises when "investor" physicians leverage their hospital referrals to require hospitals to purchase the devices they implant in their own patients, through a company in which the referring physicians has an ownership interest. QuIC has created several backgrounders on such Physician-Owned Distributors (PODs) and provided testimony and regulatory commentary to OIG, CMS and state agencies. 

• "Senate report discourages dealings with physicianowned distributorships," Compliance Today, March 2017
• "Letter to Senate Finance Committee regarding Hearing on PODs," November 2015 (Statement for the Record for the Senate Finance Committee’s November 17, 2015 Hearing entitled "Physician-Owned Distributors: Are They Harmful to Patients and Payers?") 
• "OIG Special Fraud Alert on PODs: Soon to Be the Latest in a Long History of Associated Enforcement Actions?," Quality Implant Coalition Backgrounder, April 2013
• "Key Issues Concerning PODs Under Federal Sunshine Law," Quality Implant Coalition Backgrounder, March 2013
• "PODs vs. Physician-Owned Providers of Health Care Services," Quality Implant Coalition Backgrounder, December 2012
• "Gainsharing v. PODs," Quality Implant Coalition Backgrounder, March 2012
• "Supplement to Comments on Physician-Owned Implant Companies," April 2008 (Responding to July 2007 proposed Regulations to Revise Physician Fee Schedule Payment Policies concerning definition of "Stark" law DHS "entity" and rebutting claims made in favor of POCs by their supporters) 
• "Comments on the Treatment of Physician-Owned Implant and Other Medical Device Companies under the Physician Self-Referral Law," June 2008 (Responding to April 2008 proposed Inpatient Prospective Payment System Regulations concerning factual background on different types of POCs, summarizing patient and program abuses and suggesting regulatory clarifications under "Stark" law) 
• "Supplemental Comments on the Treatment of Physician-Owned Implant and Other Medical Device Companies under the Physician Self-Referral Law," October 2008(Responding to August 2008 final Inpatient Prospective Payment System Regulations, addressing why "Stark" "indirect compensation" exception does not protect POC investments and why POCs should be deemed to "perform" DHS) 
• "Testimony Concerning M.G.L. Ch. 111N, 105 CMR 970.000: "Pharmaceutical and Medical Device Manufacturer Conduct," January 2009 (Responding to December 10, 2008 Proposed Massachusetts Department of Public Health Regulations seeking clarification that physician ownership in a POC is an economic benefit that must be disclosed) 
• "Comments on the Physician Payments Sunshine Act of 2009," S. 301, May 2009 (Providing testimony in support of transparency of POC financial relations and quoting CMS and OIG concerns) 
• "Physician-Owned Implant Companies: Evidence of Product Quality Deficiency and/or Overutilization at One Hospital," QuIC Member case study, 2007