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Physician Group Practices Should Prepare Now for Changes to Productivity Bonuses and Profit-Sharing Requirements under the Stark Law | Insights

Beginning Jan. 1, 2022, the Centers for Medicare and Medicaid Services (CMS) will enforce new Stark Law 1 requirements for physician compensation models in group practices. Group practices that rely on generating revenues through intra-group referrals of “Designated Health Services” (e.g., clinical laboratory services, therapy services, imaging services, outpatient prescription drugs, durable medical equipment, etc.), including for ancillary services billed under the In-Office Ancillary Services exception, should start planning now to ensure that their compensation plans – specifically, their productivity bonuses and profit-sharing plans – will remain in compliance with the Stark Law. The Stark Law is a strict liability statute, meaning even a technical misstep in a compensation plan can make the group’s Designated Health Services (DHS) non-billable under Medicare. Accordingly, it is important that group practices ensure continued compliance when the 2022 requirements bec

Productivity Bonuses and Profit-Sharing Requirements under Stark Law

Advertisement Physician Group Practices Should Prepare Now for Changes to Productivity Bonuses and Profit-Sharing Requirements under the Stark Law Wednesday, April 28, 2021 Beginning Jan. 1, 2022, the Centers for Medicare and Medicaid Services (CMS) will enforce new Stark Law 1 requirements for physician compensation models in group practices. Group practices that rely on generating revenues through intra-group referrals of “Designated Health Services” (e.g., clinical laboratory services, therapy services, imaging services, outpatient prescription drugs, durable medical equipment, etc.), including for ancillary services billed under the In-Office Ancillary Services exception, should start planning now to ensure that their compensation plans – specifically, their productivity bonuses and profit-sharing plans – will remain in compliance with the Stark Law. The Stark Law is a strict liability statute, meaning even a technical misstep in a compensation plan can mak

Breaking Down the New Stark Law and Anti-Kickback Statute Final Rules | Murtha Cullina

To embed, copy and paste the code into your website or blog: In late November, the Centers for Medicare and Medicaid Services and the Office of the Inspector General released their final rules revising the Physician Self-Referral Law (the “ Stark Law”) and the Anti-Kickback Statute. The changes are sweeping and while they are generally designed to facilitate coordinated care, some of the changes will impact providers more broadly. Most provisions of the final rules are effective on January 19, 2021.  The following is a brief overview of the hundreds of pages of rules and commentary: The Stark Law Final Rule New Value-Based Exceptions: New exceptions were created to permit compensation arrangements in the context of value-based arrangements designed to coordinate and improve the quality of care for patients and to lower costs.

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