Phase III of Stark II is here. You need to know how to comply with these new rules. In addition, CMS has released additional proposed changes to the Stark Law in its annual physician fee schedule update. According to CMS, many of these modifications are needed to tighten any loopholes that currently exist. Among the proposed changes are:
- Prohibit certain “per click” leases and percentage compensation arrangements
- Eliminate many “under arrangements” joint ventures
- Curtail the use of the in-office ancillary services exception
If enacted, these changes likely will have a significant effect on many existing legitimate business arrangements. Compliance officers and in-house counsel at your organization will need to be prepared to adapt and respond to these new challenges to ensure continued compliance in this regulatory environment.
Join HCPro on Tuesday, September 18 at 1 p.m. (Eastern) for the live 90-minute audioconference Stark Law Update: The latest news and real-world compliance strategies. You will learn the implications of the proposed changes to the Stark Law. You’ll also learn how to operationalize aspects of the Stark Law, including the proposed changes. Two expert healthcare compliance attorneys will discuss the proposed changes, recent Stark Law cases, the government’s use of the rule as the basis for violations of the False Claims Act, and the upcoming release of Phase III.
TAKE A LOOK AT THE AGENDA
- Stark Phase III
- Overall impact
- Stand in the Shoes
- Fair Market Value Safe Harbor
- Non-Monetary Compensation Exception
- Rural Providers
- Personal Services Exception Holdover
- Proposed changes to Stark in 2008 Physician Fee Schedule
- Percentage compensation
- In-office ancillary exception
- Per-click arrangements
- Services furnished “under arrangement”
- Anti-markup provision related to diagnostic tests
- Phase III v. 2008 Physician Fee Schedule
- Operationalizing Stark
- Practical applications
- Operational Challenges
- Live Question & Answer Session
Yes! I want to register—how do I sign up?
At the end of the audioconference, you will be able to:
- Understand CMS’ proposed changes
- Identify the affect of the proposed changes on upcoming arrangements
- Understand the exceptions and practical applications of operationalizing Stark
- Recognize the overriding issues related to Stark
- Predict what to expect in Stark II Phase III
In addition to the expertise and advice presented during this audioconference, you’ll also receive a slide presentation of the program materials and these valuable tools:
- Sample form for documenting incremental expenses
- Reconciliation document
- Sample tracking form
- Medical Director time sheet
MEET THE SPEAKERS
Robert A. Wade, Esq., Partner, Baker and Daniels, LLP. Robert concentrates his practice in representing a variety of health care clients. His specialization includes representing clients with respect to the Stark Act, Anti-Kickback Statute, False Claims Act, and Emergency Medical Treatment and Active Labor Act. For complete bio, click here.
Ramy Fayed, Esq, Associate, Sonnenschein, Nath & Rosenthal LLP. Ramy works in his firm’s Health Care Practice Group. He handles a variety of matters including: counseling health care providers on federal and state health care program compliance; reimbursement; fraud and abuse; and privacy issues. For complete bio, click here.
Have questions? I’m here to help.