CMS has posted a new Stark advisory opinion

CMS has posted a new Stark advisory opinion on its website.

The opinion addresses the following question:

Your request pertains to a physician recruitment arrangement (the

“Arrangement”) that was originally made between the Hospital and [name redacted] (the “Physician”) and which was later amended to include [name redacted] (the “Medical Group”), the physician-owned medical group practice into which the Physician was recruited. Specifically, you seek a determination regarding whether the Hospital was required under the physician self-referral statute, section 1877 of the Social Security Act (the “Act”), to include an excess receipts provision in the Arrangement and, if not, whether the Hospital may now amend the income guarantee loan agreement portion of the Arrangement to delete the excess receipts provision.

http://www.cms.hhs.gov/PhysicianSelfReferral/Downloads/CMS-AO-2007-01.pdf

About the Author

Reed Tinsley CPA

This article is written by Reed Tinsley, a Houston, TX-based CPA with over 30 years of experience advising physicians and medical practices across Texas and the United States. Reed holds certifications as a Certified Valuation Analyst (CVA), Certified Healthcare Business Consultant (CHBC), and Certified Financial Planner (CFP), specializing exclusively in the healthcare sector. He is a published author, nationally recognized speaker, and trusted advisor to physicians on accounting & tax, practice management, and financial planning. Schedule a Free Consultation.