New On Call Service Policy
Effective May 31st, 2023
Dear Colorado Optometric community,
As many of you already know, the co-management model and anti-kickbacks/Stark law violations are under increased scrutiny by federal regulators to ensure fair patient practices. At Omni Eye Specialists (“Omni”), we believe in the co-management model and will continue to operate under this model as an effective means of providing patients with proper and timely care and treatment. However, we must ensure continued compliance with applicable laws to protect the Colorado Optometric community and ourselves from any allegations of wrongdoing.
In a recent internal compliance review, it has come to our attention that some Optometric physicians may be advising their patients on their practice websites and/or on after-hours phone messages to contact Omni directly, which has the unintended effect of using Omni as the Optometric physicians’ on-call service.
The use of Omni as your on-call service in this manner without fair market value compensation may be considered a kickback/Stark Law violation. To ensure our ability to provide exceptional patient care and ensure compliance with all applicable laws, Omni must receive a direct referral from you, the patient’s primary care eye physician, for all after-hours patient emergencies unless the patient is or has been an Omni patient.
If, after consulting with your patient, you believe your patient needs Ophthalmology services and/or you would like to consult with an Omni Ophthalmologist or Optometrist after hours, you may do so by personally by contacting Omni at (303) 377-2020. An on-call provider will return your call and advise you of the appropriate course of action.
This notice shall serve as our formal request to remove Omni’s name and number from any after-hours voicemail, messaging, and/or website. Omni has not ever been and can no longer serve as an on-call service. Omni remains available to continue to provide after-hours service to you directly and for your patient referrals. However, Omni cannot take direct calls from patients that are not existing patients of Omni or have not been Omni’s patients in the past.
After May 31, 2023, should one of your patients directly contact Omni after hours without a proper referral from you, and we have not previously established care with them, the patient will be advised to contact you directly for service.
Thank you for your ongoing support.