Healthcare providers besides physicians can also violate the Anti-Kickback Statute. And, do not think that only physicians can make illegal refurrals. Paying anyone something of value for patient referrals—even a marketing company—can be illegal.
Southern District of Texas Press Release:
At the time of their pleas, they admitted that from 2014 through 2016, both obtained patient referrals by paying marketers and patients. Nwankwo further admitted to bribing a physician to authorize medically unnecessary home health services for Hefty patients.