The Illinois Appellate Court held that a percentage-based fee arrangement between a physician group and a medical billing company was prohibited and void under the state’s Medical Practice Act (MPA), 225 ILCS 60/22(A)(14) (2008). A group of sport medicine physicians contracted with the defendant company to provide billing, accounts receivable, and collection services at a rate of 4.5 percent of all reimbursements and 6.25 percent of all claims not originally processed by the defendant. The plaintiff sued, alleging the defendant breached the contract by failing to perform services. In response, the defendant argued that the contract was void under the MPA. The trial court agreed with the defendant and granted summary judgment. Affirming on appeal, the Appellate Court found that this type of percentagebased fee splitting arrangement, though common in physician arrangements with billing companies, is void in Illinois “irrespective of the purpose and common practices involved in medical billing agreements.” The court was concerned that fee splitting arrangements could lead to fraud and abuse, because the physician might be motivated by financial selfinterest rather than the professional’s competence. However, the Court expressly noted that other fee arrangements, such as a flat-fee based upon the volume and complexity of the services, would probably be valid and enforceable. The court applied a bright-line rule, finding that the MPA bans sharing, pooling, dividing, or apportioning professional fees, regardless of the reason or whether the parties’ agreement implicates the anti-fraud and abuse policies behind the MPA. Ctr. for Athletic Med. Ltd. v. Independent Med. Billers of Ill. Inc., 889 N.E.2d 750 (Ill. App. Ct. 1st Dist. 2008). The decision is likely to be appealed to the Illinois Supreme Court. If affirmed by the Supreme Court, or not appealed, this decision would have significant implications on medical providers who will be forced to make material changes to their arrangements with billing companies.