Yes. §400.9935 includes review of clinic referral contracts among the director’s statutory duties — and compensation-based referrals also warrant legal review.
Clinical governance reviewed by Armando A Falcon, MD (FL ME 84789) · Florida regulatory framework reviewed August 2026.
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.
Reviewing referral contracts is a defined director responsibility — the arrangements should be known and reviewed, not left unexamined.
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.
Disclaimer — B2B clinical-governance & compliance education only. This content is general business, clinical-governance, and compliance information for healthcare practices. It does not create a physician-patient relationship, provide patient-specific medical advice or prescribing authority, or constitute legal advice. Requirements vary by ownership, services offered, provider credentials, payer model, facility type, and whether a practice is licensed or exempt — clinics remain responsible for independently verifying the current laws, rules, and professional requirements that apply to their structure and services before implementation.
Florida Statutes §400.9935 — Clinic responsibilities & Medical Director
Florida Statutes §817.505 — Patient brokering
Florida Statutes §456.054 — Kickbacks; prohibited
Medical Director — Owner Guide — medical director services
All Florida medical-director resources
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