MFMD guide · AHCA clinic governance

Does an AHCA Medical Director review referral contracts?

The right answer depends on the facility’s actual structure, regulatory status, services, payer model, and licensed team. This guide organizes the facts that should be resolved before a decision is made.

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Direct answer

Yes. §400.9935 includes review of the clinic’s referral contracts or agreements among the Medical or Clinic Director’s statutory responsibilities. Where compensation is involved, those relationships also deserve legal review, because Florida has patient-brokering and kickback statutes.

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What is the director’s role in reviewing referral contracts?

Reviewing referral contracts is a defined director responsibility — the arrangements should be known and reviewed, not left unexamined.

When should counsel review a referral relationship?

Any referral relationship involving compensation should be reviewed by counsel against Florida’s patient-brokering (§817.505) and anti-kickback (§456.054) provisions. Governance review is not a substitute for legal advice on these questions.

Primary sources

Review the cited source before applying the answer to a facility.

How to use this guide

Separate the public question from the facility decision.

First confirm the facility type, AHCA or exemption status, payer model, licensed roster, and services. Then check the current official source and document who evaluates, prescribes, orders, administers, supervises, and escalates an exception.

MFMD can structure facility governance and present the proposed services and responsibilities to a physician. Clinical authority and acceptance remain with the reviewing physician.

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