Corporate Compliance

Stark II Phase III released

Health Care Auditing Strategies, October 1, 2007

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Key changes in indirect compensation, physician recruitment, and personal service

Editor's note: This article first appeared courtesy of HCPro's breaking news e-mail service.

As if the potential Stark changes included in the proposed Medicare Physician Fee Schedule (MFPS) weren't bad enough, CMS issued the long-awaited Stark II Phase III final rules in September. The implementation date is December 4. "Although CMS made some pragmatic changes that may make it easier to comply with the Stark law, CMS implemented other changes that likely will require many existing hospital-physician arrangements to be restructured. Given the pending physician fee schedule proposals to the Stark law, it's going to take some time to fully assess the effect of Phase III," says Ramy Fayed, associate at Sonnenschein Nath & Rosenthal, LLP, in Washington, DC.

"We were hoping for some consolidation of the rules," adds Sara Kay Wheeler, Esq., partner at Powell Goldstein, LLP, in Atlanta.

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