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A recent fraud alert published by the OIG listing "suspect hospital incentive arrangements" in physician recruitment practices is compelling hospital executives to review their recruitment strategies. "What is new about this fraud alert," says an attorney, "is that the OIG has put them into one document as an indication of its enforcement priorities."

The release of the "safe harbors" regulations by the Department of Health and Human Services has left a variety of important issues unresolved. Health care attorneys and their clients are now poring over the new regulations, trying to determine, among other things, how much risk tolerance to accept in relation to the new restrictions, and what level and types of monitoring the federal government will apply. Ultimately, say many experts, the regulations could result in a strong trailoff in joint venture volume.

Gail Wilensky, Ph.D., head of the Health Care Financing Administration, has time on her side. Four months into the job, Wilensky has received high marks from various segments of the health care field for her broad outlook and no-nonsense approach to numerous issues. Still, final judgment is being reserved until Wilensky is forced to address some tough issues. And in today's environment, there are plenty of tough issues ahead--the 1991 budget, for instance.

HHS and IRS are good examples of federal agencies that, each responsible to its own unique regulatory, manage to frequently undermine congressional health policy intent.