KIE: Increasing numbers of physicians are investing in outpatient facilities to which their own patients may be referred. These investments raise ethical questions about conflicts of interest, leading to consideration of physician income over patient welfare, and to overbilling of payors. There have been calls for legislation prohibiting physicians altogether from investing in health facilities or from referring patients to facilities in which they have a financial interest. Morreim believes that such legal prohibitions could intrude on the physician patient relationship, restrain trade, and deter the development of better, more cost-efficient ways of delivering care. She argues that utilization review, quality assurance, and a judicially fashioned, case-specific common law remedy are better ways to protect the interests of payors and patients.