If you are a participating Medicare health care provider, engaged in or considering a financial transaction with a physician or group of physicians in a position to refer any of a broad array of Medicare designated health services to you, then you must structure the arrangement to comply with an exception to the Stark Law. The Stark law prohibits self-referral unless the arrangement meets an exception, and, in some cases, liability is being extended to Medicaid referrals as well. Examples of transactions governed under the Stark Law include leases of space or equipment, independent contractor services such as clinical services, lab services or medical directorships, employment agreements, income guarantees, recruitment loans or practice acquisitions, etc. The failure to comply with the Stark Law can lead to catastrophic liability under the Stark law itself and under the False Claims Act and the Civil or Monetary Penalties Law, including Program Exclusion.
This webcast was created specifically for healthcare providers, administrators and physicians, and addresses some common arrangements and pitfalls for the unwary.
In this webcast, Walter Williams, Chark Sinsel, and Jami Suver will discuss:
•The broad scope of what constitutes a ‘financial relationship”
•The general structure of some common arrangements and basic criteria for several key Stark Law exceptions
•Recent enforcement activity by type of arrangement