TABLE OF CONTENTS

1 The Columbia Story and an Overview_________________________21.1 In September 1993____________________________________________21.2 In February 1994______________________________________________21.3 In April 1995__________________________________________________21.4 In March 1996_________________________________________________21.5 In August 1996________________________________________________21.6 In October 1996_______________________________________________31.7 In November 1996_____________________________________________31.8 By December 1996____________________________________________31.9 In February 1997______________________________________________31.10 In March 1997_________________________________________________31.11 In July 1997___________________________________________________4

2 Corporate Philosophy___________________________________________5

3 Allegations of Unsavory Behavior At The Time Of The FBI Raids_________________________________________________________________6

3.1 PACMAN activity_______________________________________________63.2 Shortchanging the community and patients____________________63.3 Relationships with doctors_____________________________________63.4 Misusing integrated systems__________________________________73.5 Market control_________________________________________________73.6 Marketing_____________________________________________________83.7 Billing practices_______________________________________________8

4 Fraud Investigation_____________________________________________94.1 The July 1997 FBI raids________________________________________94.2 A new chairman and a new approach__________________________94.3 HCA's Track Record___________________________________________94.4 Using this information to press issues in Australia____________104.5 Vindicated again_____________________________________________104.6 One Whistle Blowers Battle___________________________________104.7 Court actions_________________________________________________104.8 The Unfolding Investigations_________________________________114.9 Breaking up the company____________________________________11

5 The Nature of Fraud Allegations and Practices______________125.1 Billing Fraud_________________________________________________125.2 Patient care__________________________________________________135.3 Employees___________________________________________________145.4 Relationships With Doctors___________________________________145.5 Accreditation processes______________________________________155.6 Marketing____________________________________________________15

5.7 PACMAN activities____________________________________________15

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1 The Columbia Story and an Overview

Columbia Healthcare was formed in July 1988 by Richard Scott, a lawyer and Richard Rainwater, a financier. It was formed in partnership with 120 physicians. It bought two hospitals in El Paso, Texas. In May 1990 it bought a laboratory company and listed on the stock exchange.

1.1 In September 1993

Columbia merged with Galen Health Care which had earlier been spun off from Humana. It now owned 99 hospitals in the USA and internationally. It expanded its policy of selling ownership stakes to physicians in order to bind them to the corporations profit mission

1.2 In February 1994

Columbia merged with Hospital Corporation of America (HCA) to form Columbia/HCA, now a US $10 billion company. Scott becomes president and CEO. HCA's chairman and CEO Thomas Frist MD Jnr became vice chairman. Columbia/HCA now enjoyed the political support of the two Frist family US senators.A year later Scott moved the headquarters from Louisville to Nashville.

1.3 In April 1995

Columbia/HCA acquired Healthtrust for US $ 5.6 billion. McWhorter, Heathtrust's CEO became chairman but was later replaced by Scott.

In a contentious purchase which divided the church Columbia/HCA acquired half of a Roman Catholic group in Cleveland in May 1995. During 1995 Columbia/HCA purchased or formed joint ventures with 33 not for profit hospitals.

1.4 In March 1996

Columbia moved to purchase the not for profit HMO's Blue Cross and Blue Shield. This was met with a public outcry. Columbia/HCA persisted in its efforts but when the FBI raided its hospitals in March 1997 it was forced to abandon the deal.

1.5 In August 1996

The New England Journal of Medicine published two articles by Robert Kuttner attacking Columbia/HCA's business practices and its corporate philosophy.

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1.6 In October 1996

the 60 Minutes national TV program screened a hard hitting exposure of Columbia/HCA's practices.

1.7 In November 1996

Columbia/HCA's PACMAN activity in purchasing not for profit community facilities received another setback when the California's attorney general blocked its $202 million bid for the assets of San Diego-based Sharp Healthcare. He claimed that Columbia/HCA undervalued the system.

1.8 By December 1996

Attorney generals across the country had stepped in to scrutinise and check Columbia/HCA's purchase of not for profit hospitals. It had acquired only 17 during 1996.

Frustrated in its profitable PACMAN activities Columbia turned its eyes elsewhere. It made a bid to acquire Value Health, a benefits management company. It also looked to expand its international operations. It bought a managed care group in the United Kingdom.

Representative Pete Stark, who years before piloted the Stark anti-kickback legislation into law was particularly critical of corporate for profit medicine and of Columbia/HCA. He said "the for-profit chains have the minds of piranha fish and the hearts of Doberman pinschers." He indicated that Columbia/HCA was "the PACMAN of the industry." On another occasion referring to Columbia/HCA executives he stated "Hopefully they will all be in jail soon for the crimes they have committed across the country."

1.9 In February 1997

Scott claimed that 1996 was the company's best year ever. Its net income was US $1.5 billion on US $19.9 billion revenues. Its stock reached US $43.88, an all time high. It owned over 350 hospitals. It announced its plans to spend US $1 billion to enter and rejuvenate the Australian health care marketplace. It bid to buy the French company Generale de Sante Internationale (GSI), the largest in Europe.

1.10 In March 1997

Federal agents raided Columbia/HCA's El Paso operations, the facilities where Columbia first began its controversial policy of encouraging doctors to buy stakes in its hospitals. This circumvented the intention of the Stark anti-kickback laws.

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There was widespread adverse publicity about the company's billing practices and its relationship with doctors. The New York Times published the results of its analysis of the company's disturbing billing practices.

Columbia/HCA abandoned its attempt to enter Australia and its bid for GSI was rejected. Australia, France and medical associations in Europe were all well informed of the concerns about the company and in possession of documents.

Scott arrogantly declined to talk publicly about Columbia/HCA's fraud problems and it was left to Thomas Frist to placate critics.

1.11 In July 1997

Federal agents executed search warrants across the USA seizing documents relating to laboratory and home care services. Scott resigned and was followed soon after by David Vandewater, president and COO. Thomas Frist became chairman. Columbia approached Tenet/NME with the view to am merger. This would have enabled it to capitalise on Tenet/NME's experience in a similar situation. The merger fell through.

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2 Corporate Philosophy

The company saw itself as providing "fast-medicine". It modeled itself on Macdonald's and Walmart. In promoting the Macmedicine model of care Scott followed NME's John Bedrosian in arguing that "free market, competitive forces should be the driver". He was scathing about not for profit health care and did not think that they should be in business. His attitude to the community's health, to preventive medicine and to the care of the poor is reflected in his rebuttal of the concerns of others . He stated "We are not in the health care business. We are in the sick care business."

Columbia/HCA adopted a very aggressive commercial approach. It paid little service to the ethics of the professions and employed teams of lawyers to stretch the law as far as it could. Profit and growth were the measures of success and dominated all decision making.

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3 Allegations of Unsavory Behavior At The Time Of The FBI Raids

3.1 PACMAN activity

Columbia/HCA's lawyers allegedly moved in and opened secret negotiations to buy or merge with not for profit community hospital directors. The public and doctors were not told until the sale was completed. Often the sale price was not made public.

Regulations required for profit chains to continue preexisting services after buying not for profits. To circumvent this non paying community services run by not for profits were quietly terminated prior to the sale. Community assets were bought at prices well below their market value. Board members and executives selling not for profits benefited financially. There were concerns that they were offered inducements which may have violated laws against bribes. There were claims that money intended for community projects was subverted.

3.2 Shortchanging the community and patients

Columbia was accused of anticompetitive behaviour and of giving financial considerations priority over community needs. Decisions were made centrally and not at the community level. There was a lack of commitment to any particular community.

Columbia/HCA was alleged to have closed needed local community hospitals once it had secured market position with control of all hospital facilities in the region.

It was claimed that when compared with not for profit services it did not invest in costly services as readily and the amount of charitable and indigent care provided was much lower. Charges were consistently higher and any cost savings were due to one factor only, staff reductions. This was not as claimed due to purchasing power. They were accused of cherry picking profitable admissions, cream skimming and patient dumping

Larger profits were made by Columbia/HCA through charges which were substantially higher, by not providing expensive and less profitable services, and by reducing staff levels. These profits were passed to shareholders and did not benefit the community.

3.3 Relationships with doctors

As with Tenet/NME control of the profession by a variety of financial strategies was critical to Columbia/HCA's success. The business community saw nothing wrong with such unethical and often illegal practices. The Wall street journal reported that Columbia/HCA received plaudits from Wall Street for its ability to form beneficial alliances with local doctors.

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The company allegedly offered doctors incentives to secure their compliance, ensure their loyalty and their patients. Doctors were offered investments in the hospital in such a way that the profits made would be linked to their increased utilisation.

There are allegations that doctors were offered fishing and hunting trips in Texas, Mexico, the Caribbean and Alaska as inducements. They were paid illegal kickbacks including vacations, free offices, rent and opportunities to invest. These were exactly the sort of allegations made about Tenet/NME 6 years earlier. Columbia/HCA allegedly used its power over physicians to secure profitable patients for their hospitals by "cream skimming".

Columbia/HCA's business strategies in dealing with doctors were particularly unpleasant. It is claimed to have used confidential information obtained during failed merger negotiations to improperly recruit physicians. It assured doctors joining its clinics that the company would use all their resources to ensure that any competing medical services failed. They were alleged to have used uncompetitive strategies to destroy competition from rival clinics.

3.4 Misusing integrated systems

While Columbia/HCA strongly promoted its integrated system this served the company's shareholders and not the community. Instead of integrating with other services it was claimed that its "sole goal was to divide and conquer and protect their company profits."

Its behaviour was anticompetitive. Robert Kuttner analysing its conduct indicated that "Columbia's strategy works not just to produce cost economies but also to prevent shopping around and to allow Columbia/HCA to impose conditions that doctors and patients might otherwise resist."

It used its own integrated system to maximise services and profits. It had a higher number of payments for costly outpatient services like home care. It charged more for these services and used the services more. This was facilitated by agreements with doctors which circumvented the anti-kickback laws by giving them a financial interest in local integrated systems. One competing home care service went to court alleging unfair practices in an attempt to exclude them from the market in Texas and nationwide. They accused Columbia/HCA of offering hospital staff incentives to refer patients to home care facilities affiliated with Columbia/HCA

3.5 Market control

Kuttner stated that "Columbia/HCA insists that medicine is a business, and increasingly imposes its rules on the competition game." It attempted to become a managed care company while remaining a provider. Carl Ginsburg writing in The Nation said "Add Columbia's growing interest in owning managed care systems, which control health care access, and every piece of the patient for profit puzzle is in place."

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3.6 Marketing

Like Tenet/NME the company considered marketing as a most important activity and central to success. Its marketing budget sometimes exceeded US $100 million a year. It was particularly aggressive in attacking its competitors in its advertising. Its public relations campaigns portrayed not for profits as social parasites.

In prosecuting its PACMAN activities the issues were often obscured by crafted press releases and public relations campaigns which misrepresented the nature of the "joint ventures".

There were concerns about the way in which hospitals obtain their accreditation and the way they advertised some of this. They allegedly falsely advertised suggesting that they had won the Baldridge accreditation award.

3.7 Billing practices

The New York Times analysis identified "upcoding" occurring in Columbia/HCA hospitals. About 100 illnesses such as pneumonia could be coded as simple pneumonia ($3150) or as complex pneumonia ($6800). Columbia gave employees doing the billing "focus codes" on which to concentrate. Columbia/HCA hospitals had a very much higher proportion of complex pneumonia codings. This practice of inflating the seriousness of the illnesses was very profitable because of the large numbers of codes allowed

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4 Fraud Investigation

4.1 The July 1997 FBI raids

Following the FBI raids on Columbia/HCA across the USA in July 1997 Richard Scott arrogantly rejected the allegations of misconduct and refused to speak publicly. He insisted they had done nothing wrong. He obviously believed this. Thomas Frist was forced to do the public speaking. Soon after the board forced Scott and his henchman VanderWater to resign. Scott received a $12.4 million severance package and the company later bought him a mansion to live in. He eventually walked away with more than US $17 million. Over the succeeding months there was a purge of a number of senior staff and some lawyers.

4.2 A new chairman and a new approach

Thomas Frist, the past chairman of HCA became the new chairman of Columbia/HCA. He stopped denying the allegations. Instead he claimed that he was radically restructuring the company and making major changes in policy and philosophy. In doing so he implicitly admitted to many of the complaints made about the company.

Frist claimed that he was going to make the company more like the HCA which he had run, implying that HCA was some sort of a role model. It would be less aggressive and more patient centred. I was very critical of Frist and pointed out that his statements were no more than a public relations exercise - a facade. If Columbia/HCA actually abandoned its practices its profits would fall and it would lose the support of the market.

Unlike Tenet/NME Columbia/HCA under Frist has not tried to reject or deny the allegations. Instead it has made conciliatory noises and sought to reach some sort of early settlement with government. Frist claims that he had been unhappy with Scott's style. Frist publicly set aside US $1 billion to settle with the government and promised shareholders that it would be settled by March 2000. By April 2000 the government had not yet taken the bait.

On 25 October 1997 The Dallas Morning News reported "We have zero tolerance for anything wrong," Dr. Frist said, pounding his fists on the lectern. "We have got to have the public trust." Frist had been chairman of HCA and vice chairman of Columbia/HCA.

4.3 HCA's Track Record

In my submissions I pointed out that HCA under Frist had an appalling track record. It was a disturbing role model. The 1993 DAY ONE television program had exposed misleading advertising, fraudulent admission of patients who did not need admission and the misuse of teenagers for profit. HCA had paid a large settlement for similar practices in Texas.

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4.4 Using this information to press issues in Australia

In August 1997 Queensland was revising its state hospital licensing regulations. I used Frist's admissions and planned changes to press Queensland and other states to set in place regulations which would give probity regulations teeth and control corporate behavior by forbidding similar business practices (e.g. incentives). The letter gives more information about Columbia/HCA's statements at this time and quotes from articles.

4.5 Vindicated again

Within the next 12-18 months my assertions about HCA were more than confirmed. Billing irregularities are the easiest of the major fraudulent practices to identify and prove. The fraudulent practices used by Columbia/HCA had been introduced into HCA and into Quorum and Healthtrust while the latter were owned by HCA. The allegations went back to 1984. Frist was chairman of HCA during this period. The investigation into these practices had started as early as 1993. The Qui Tam whistle blower lawsuits which the government joined had been lodged by James Alderson in 1993 before Columbia merged with HCA in 1994. Clearly many of the criminal practices had come to Columbia from HCA with Frist. More than 200 hospitals from the HCA stable in at least 37 states were named as defendants in the lawsuit against Columbia/HCA.

4.6 One Whistle Blowers Battle

The NY Times 18/10/98 told the fascinating story of James Alderson against "the huge Hospital Corp. of America and three of its corporate spinoffs" who "had cheated the government with bogus expense claims." The paper described it as "a battle so far fetched -- one man versus four huge corporations". The discovery "made by one man at a small rural hospital ultimately unraveled a nationwide, systemwide scheme". The story of health care fraud is the story of regulatory failure. It is the story of citizens who have had the courage to act against the powerful, and their persistence in the face of overwhelming odds.

While the press reported this news prominently it was extremely kind to Frist. No one has confronted him with his claims about a benign and patient centred HCA under his stewardship or with his personal involvement in all this. His father and his brother were respected and admired US senators. The Frist family has enormous political power.

4.7 Court actions

Much of the initial evidence used in court came from staff in the company. Some had cooperated with police, wearing hidden recording devices while speaking to company executives The first court action was taken against four executives in Florida. A fifth was given indemnity in return for evidence. The case came to court in July 1999. Some executives were jailed in December. The justice department commenced civil and criminal proceedings against Quorum and Columbia/HCA in October 1998. It joined a

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whistle blowers Qui Tam suit. Healthtrust and HCA were now part of Columbia/HCA. Over 12 separate Qui Tam actions had been taken by whistle blowers.

4.8 The Unfolding Investigations

There were further FBI raids in El Paso Texas in February 1998, and in Las Vegas in May 1998. The tax office was involved and demanded a multimillion payment. The US Securities and Exchange Commission (SEC) started investigating in 1998 to determine whether the executives gave investors accurate figures. A number of shareholder suits were also commenced and insurers later advised that they too suspected that they had been overcharged. More whistle blower suits were unveiled and by 1999 11 states had joined in the investigations. The St. Petersberg Times (25/2/99) reported that the justice department had asked for another US $5 million to fund its investigation of Columbia/HCA "where fraud has been alleged in virtually every aspect of the largest health care conglomerate in the U.S."

4.9 Breaking up the company

Faced with a massive fraud settlement Frist started to break up the company and make it much smaller. Plans to buy Blue Cross and other groups were abandoned. Large number of hospitals and subsidiaries were sold. The PACMAN activity was reversed. Many hospitals were sold back to not for profit groups. Not for profit groups had banded together and successfully discredited Columbia/HCA. Its interest in the catholic hospitals, which had had caused so much angst, were sold. It reversed its integrated health care policy and sold off its Home Healthcare subsidiary. In addition it spun off 64 hospitals as two separate not for profit companies - Triad (42 hospitals) and LifePoint.

This gave it a war chest for its legal battles and fines. It bought back US $1 billion in shares. It is difficult to know if it has been fulfilling conditions required by government prior to reaching a settlement which would allow it to continue receiving Medicare funding. In the same situation Tenet/NME sold all its rehabilitation hospitals and subsumed its other specialty hospitals into its psychiatric division most of which was then sold as a condition of the settlement. This allowed it to plead guilty in the name of a single subsidiary, retain Medicare funding and claim that this one division was an infected appendage which had been amputated.

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5 The Nature of Fraud Allegations and Practices

On 11 May 1997 before the second FBI raids the New York Times echoed my assessment of the impact of market principles on health care. It summarized Columbia/HCA's enormous financial success by saying "At the heart of that achievement is an aggressively competitive vision of medical care, one that applies the practices of corporate America to an industry still dominated by not-for-profit institutions."

Also "These practices include not only in-your-face marketing, but hospital takeovers, cost-cutting and layoffs, volume purchasing, complex pricing strategies and large monetary incentives for managers who meet financial targets."

and "In 1995, 25 percent of Columbia's administrators won bonuses of at least 80 percent of their salaries, according to the Advisory Board, a consulting company. Thirty percent received none."

Staffs were sent score cards setting out their monthly targets. Administrators who failed to attain their monthly budgets had to write extensive reports explaining what happened and how they planned to boost profits. The 10 lowest performers had to meet with Scott and senior managers

Similar incentives were at the heart of the problems in Tenet/NME's empire. They called it "plan". Bonuses and job prospects were based on "meeting or exceeding plan". This severely dysfunctional practice is central to microeconomic reform. Incentives linked to financial performance are universally adopted even in Australian health care corporations.

5.1 Billing Fraud

Some expenses incurred by companies in running hospitals are claimable against Medicare. Columbia/HCA claimed reimbursement for advertising and marketing, for expenses incurred in recruiting doctors from competitors, and for running hospital gift shops and cafeterias. None of this was legal. It also illegally shifted its hospital overhead expenses to its home health care operations then claimed them. It used its integrated system of acquired corporate subsidiaries to fraudulently obtain federal reimbursement. There were allegations that staff were told to hide documents from Medicare

An affidavit claimed that Columbia/HCA acquired a group of Olsten home care agencies for a price far lower than comparable deals, but then entered into management agreements with the seller. These allowed Columbia to shift acquisition costs that are not reimbursable by the government into administrative costs that are. In April 1999 Olsten paid US 61 million to settle a fraud action related to one of the rackets involving Columbia/HCA.

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The Internal Revenue Service's demanded $267 million in taxes for 1993 and 1994 to pay among other things back taxes on a reserve fund kept in case Medicare challenged Columbia/HCA's bills. Columbia/HCA hospitals had prepared two costing documents - one actual costing to fall back on and another allegedly fraudulent set to try out and see if Medicare would accept it. If Medicare had objected they would have offered the other.

A 1997 affidavit alleges the Texas division of Columbia/HCA made false billings for hospital supplies and set up a shell medical laboratory to funnel kickbacks to doctors. Senior staff it appears knew of the practices.

In December 1998 a second whistle blower suit was unveiled. After lodging his suit in 1995 this whistle blower returned to his job gathering information for the government. The suit alleged that Columbia/HCA routinely submitted false documentation to Medicare, Medicaid and CHAMPUS, a civilian health-insurance program for the military. Interestingly the allegations in this suit were limited to about 100 hospitals owned by Columbia prior to its merger with HCA in 1994.

The NY Times (31/12/98) reported that "the latest suit also for the first time brings claims that Columbia hospitals manipulated expenses to increase reimbursement for outpatient services like home care, sometimes by misreporting expenses associated with the acquisition of companies involved in those businesses".

In February 1999 the government filed an amended claim accusing “- - - the hospital group of falsifying claims in every report submitted since 1985."

The NY Times (9/4/99) reported that the Justice Department had joined a third Qui Tam lawsuit alleging that Columbia/HCA Healthcare Corp. and Curative Health Services Inc. defrauded Medicare. Curative managed wound care centers at 42 Columbia/HCA hospitals. They allegedly charged Medicare for costs to which they were not entitled, including excessive over-inflated management fees, advertising and even for US $400 kickbacks which Columbia/HCA was paying Curative Health for referrals.

Columbia/HCA was accused of ordering unneeded lab tests, giving illegal inducements to Texas doctors and inflating costs elsewhere. Columbia hospitals operating throughout the United States were claimed to be involved in fraudulent bills for laboratory tests.

5.2 Patient care

A study in 1996 compares Columbia/HCA hospitals with not for profit hospitals had shown deficiencies in the range of care, staffing, and service to the community. After the FBI raids current and former hospital employees claimed that Columbia's aggressive profit first practices began "affecting patient care immediately after Columbia's 1994 takeover of Hospital Corp. of America".

Modern Healthcare (15 Sept 97) reported that "Consumer groups, nurses and labor advocates have contended for some time that Columbia reduces staffing to unsafe levels

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at its hospitals in an effort to control costs." Investigations in Kentucky and in California revealed staffing deficiencies resulting in problems in care. Regulations had been breached and one patient had died.

The Denver Post 4/3/99 reported that part of HealthONE for-profit system, which is co-owned by Columbia/HCA Healthcare was nearly closed in 1995 and was being reviewed again. As in the aged care industry, the allegations being made could reflect a problem with staffing levels.

A CEO of one hospital claimed that she was fired for refusing to lay off staff or to force physicians to discharge small babies prematurely. Both would have compromised care

5.3 Employees

More than 2000 HealthTrust employees claim that the company improperly cut them out of a stock option program when they resigned. They are making a large claim.

The nursing unions have been in a protracted battle with Columbia/HCA.

5.4 Relationships With Doctors

Modern Healthcare (10/11/97) reported that a CEO at one of Columbia/HCA's hospitals was dismissed for refusing to indulge in illegal conduct which was likely to jeopardize patient care. The allegations include

Being pressured to hire an underling whose job would be to increase referrals to Columbia's home-care services regardless of medical necessity or the legality of the referrals. Being instructed to cut 150 staff positions at the hospital despite her objections that the layoffs would jeopardize patient care. Being pressured to threaten physicians with canceling contracts for services if they didn't shorten the costly lengths of stay of neonatal patients.

In 1992 a CEO at a Tenet/NME Hospital lodged a similar action which was very rapidly settled with a muzzling agreement. There was a single press report. The Columbia/HCA action too has received no further publicity.

An affidavit claimed that compensation was paid to doctors "as specific inducements for patient referrals to Columbia facilities". Another affidavit claims that the company set up a shell medical laboratory to funnel kickbacks to doctors in Texas.

Reports in the NY Times and Modern Healthcare indicated that "Columbia/HCA Healthcare Corp. has ordered its hospital executives to collect back rent and other money owed by doctors, as part of its reorganization and efforts to deal with a federal investigation." It also indicated that "federal prosecutors are looking into a variety of arrangements Columbia made with doctors". The extent of the practices is clear from the

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structure set up to collect the money. The Times says "President Jack Bovender demanded collection of overdue money and set up a five-person team to oversee the process".

The March 9 edition of Medicare Compliance Alert, a newsletter published by Rockville, Md.-based United Communications Group, reported that some Columbia hospitals neglected to bill physicians for rented space for up to two years. Amounts of overdue rent ranged from US $70,000 and $400,000. This must have been a very strong inducement for the doctors to keep Columbia/HCA on side by bringing in patients and then manipulating them through the integrated system to maximise profits.

Tenet NME also loaned doctors large sums on very lenient terms. Team players were sometimes not expected to repay them.

Columbia/HCA owned large numbers of physicians practices. They had contracts with the physicians and were in a strong position to exert influence. According to the NY Times 27/8/98 it was removing 900 doctors from its payroll.

5.5 Accreditation processes

According to the NY Times (11/2/98) "Sweeping federal investigations of Columbia/HCA Healthcare Corp. are focusing on whether the company cheated federal health programs and lied to a hospital accreditation commission"

El Paso investigators were examining whether the company submitted false records to the Joint Commission on Accreditation of Health Care Organizations, the main hospital accreditation group. (NY Times 11/2/98)

5.6 Marketing

An affidavit claimed that officials purportedly working in public education were in fact engaged in marketing and sales. Rather than providing health education to the community executives charged with that responsibility spent most of their time making sales calls to doctors and "hunting" for patients. A document from the home care division stated that "the primary marketing resources at the disposal of any of the Columbia home care agencies are the community education coordinator and home care coordinator."

5.7 PACMAN activities

Health Line (5/3/99) reported that the Internal Revenue Service was cracking down on some of the jointly owned not for profit hospitals as they do not comply with not for profit status and so are not exempt from tax.

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