First few Article Sentences
Many health care providers utilize independent contractors who are paid on a commission basis to assist in the sales and marketing of their health care services. However, it is important to keep in mind that the Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services has raised concerns in the past regarding commission or per click payments made to independent contractor sales and marketing representatives. In fact, the OIG suggests that sales and marketing representatives who are paid on a commission or per click basis instead be employed as W-2 employees.