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A neurosurgeon meets a neuro-monitoring device manufacturer through a colleague at an annual conference. The manufacturer approaches the neurosurgeon and his colleague and offer them the opportunity to invest (and obtain a proportional ROI) in the neuro-monitoring company joint venture which sells the neuro-monitoring devices to hospitals for utilization by neurosurgeons during surgery. The neurosurgeon is in private practice but has staff (surgical) privileges at many local hospitals and recently accepted a "Chief of Neurosurgery" medical director position, which position has the potential to provide him with the opportunity to recommend which neuro-monitoring device company to contact with. In addition to the investment opportunity, the neuro-monitoring device manufacturer has provided the neurosurgeon with the opportunity to enter into a Consulting Agreement (compensated on a flat monthly fee) to provide certain consulting services to the affiliated management company, which will then provide turn-key management/billing/administrative services to the newly formed joint venture (as well as own an interest in the JV). All is going well until the neurosurgeon and hospital with which he is a medical director are subject to an investigation by the OIG/Department of Justice.
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