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Episode 17: Let s Talk Compliance (Again!) – An Update On Fair Market Value & Commercial Reasonableness - Food, Drugs, Healthcare, Life Sciences
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Discussion on Fair Market Value & Commercial Reasonableness
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Medical groups that have division-based or service-level approaches to physician compensation should spend their summer evaluating their models in light of Stark Law revisions that go into effect on January 1, 2022. The revisions, seen by CMS as a clarification of original intent, will effectively prohibit distributions of profits from designated health services, or DHS, on a service-by-service basis.
Background
The physician self-referral law or Stark Law prohibits a physician from referring a patient to an entity with which the physician (or an immediate family member) has a financial relationship, for the furnishing of DHS including lab, imaging, and hospital inpatient and outpatient services for which payment otherwise may be made under Medicare or Medicaid, unless an exception applies. Physician group practices commonly rely on the in-office ancillary services exception (IOAS) to protect referrals for DHS among phys
Monday, May 24, 2021
Medical groups that have division-based or service-level approaches to physician compensation should spend their summer evaluating their models in light of Stark Law revisions that go into effect on January 1, 2022. The revisions, seen by CMS as a clarification of original intent, will effectively prohibit distributions of profits from designated health services, or DHS, on a service-by-service basis.
Background
The physician self-referral law or Stark Law prohibits a physician from referring a patient to an entity with which the physician (or an immediate family member) has a financial relationship, for the furnishing of DHS including lab, imaging, and hospital inpatient and outpatient services for which payment otherwise may be made under Medicare or Medicaid, unless an exception applies. Physician group practices commonly rely on the in-office ancillary services exception (IOAS) to protect referrals for DHS among physicians within the practice or