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From 1983 until 1989, petitioner practiced radiology in
Seattle, Washington. In March 1989, petitioner began practicing
at the Highline Community Hospital in Burien, Washington, as
chief of radiology.
On average, petitioner worked 14 to 18 hours a day at the
Highline Community Hospital and provided services to 100 patients
a day (over 30,000 per year). Petitioner provided patients a
broad range of services, including plain film analysis,
mammography, intravenous pyelography, computerized tomography,
ultrasound, nuclear medicine, magnetic resonance imaging, and
interventional radiology. An employee of the hospital would
screen a patient who came to the hospital and would take the
patient's name, address, and insurance information. The patient
would then go to the department with a request slip indicating
the procedure requested by the patient's doctor. The request
slip had three parts, the last of which was a pink slip that
petitioner used for billing purposes. The Highline Community
Hospital billed the radiology patients for the use of its
equipment, and petitioner billed the patients separately for his
professional services. After petitioner performed the radiology
procedure, the fee for petitioner's services was marked on the
pink slip. The pink slips were then batched daily and sent by
courier to petitioner's billing service. Petitioner did not
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