Corporate Compliance

Make Stark compliance a priority this year

Strategies for Health Care Compliance, April 1, 2009

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Upcoming changes to the Stark Law should put financial arrangement audits at the top of compliance officers? and auditors? priority lists this year. Provisions to the Stark Law will be effective October 1. Major changes include: The elimination of unit-of-service or per-click payments for a physician who leases space and equipment to a provider who performs designated health services (DHS) for patients referred by the physician lessor. The expansion of CMS? definition of an entity that is furnishing DHS to include the person or entity that has performed services billed as DHS or presented a claim for Medicare benefits for the DHS. The prohibition of percentage-based compensation for office space and equipment, except for physician services. This year?s inpatient prospective payment system final rule amends the previous exception for office space and equipment rental and fair market value compensation and indirect compensation arrangements.

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