ketamine physician specialty

Ketamine Clinics: Does a Physician’s Specialty Matter?

Ketamine clinics are run by various provider types in the United States. In some states, mid-level practitioners (e.g., Nurse Practitioners and Physician Assistants) can practice independently. In other states, such providers can only work independently if they are supervised or overseen by a physician. However, the question then becomes whether any physician can run a

rico racketeering psychedelics

RICO and Psychedelics

RICO (or the federal Racketeer Influenced and Corrupt Organizations Act) has been a thorn in the foot for cannabis companies since, well, the dawn of cannabis companies. RICO will be just as annoying for psychedelics companies. Today I will explain what RICO is and why RICO and psychedelics will have a rocky relationship. What is

Ketamine Clinics: What is a “Referral” Under the Federal Anti-Kickback Statute?

Ketamine Clinics: What is a “Referral” Under the Federal Anti-Kickback Statute?

In a prior post, we discussed the federal anti-kickback statute (the “AKS”) and the implications for ketamine clinics. In short, the federal AKS prohibits anyone from paying or receiving anything of value for the referral of patients where a federal government healthcare payment program is the payor (e.g., Medicare, Medicaid, VA, etc.). 42 U.S.C. §