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CMS Makes Things Nonexclusive: Immediate Changes to the Stark Law Will \end{matrix} 411.356 Exceptions to the referral prohibition related to ownership or investment interests. With the increased rate of mergers and acquisitions, healthcare organizations are vulnerable to federal scrutiny. \text{Constant} & \text{20.000} & \text{3.2213} & \text{6.21}\\ var year = today.getFullYear() The argument is that but for the celebrity being in the movie the consumer would not purchase the ticket. between x, annual gross rents (in thousands of dollars), and y, selling price (in The Situation: The isolated transactions exception under the Stark Law has been used by some providers and entities to retroactively protect services arrangements that do not qualify for personal services or fair market value compensation exceptions because, for example, the arrangements were not reduced to writing before services were rendered. Their concern has been financial, yes, but also an increasing concern of compliance risk. CMS Clarifies Key Valuation Terms in the Stark Law | Jones Day Health Management Associates $260 Million, Kalispell Regional Healthcare $24 Million. Our fixed asset valuation services serve a variety of purposes for our clients, including: Anti-Kickback Statute and Stark Law Compliance ), commonly referred to as the Stark law, is a set of regulations that pertain to physician self-referral under current United States (US) federal law. Key PYA Takeaway: Guidance from prior court decisions, as well as certain previous governmental representatives, have questioned commercial reasonableness if arrangements are not profitable. Which of the following is a government sanction provided under the Stark regulation? So, while it may require effort, and in some cases could be difficult to achieve, finding fair market value is a must. The Stark Law prohibits physicians from referring patients for services to entities in which the physician or _____ has a financial interest. Avoiding Illegal Service Referrals: The Stark Statute Explained A and B - not be conditioned on referrals & allow the physician to establish medical staff membership at other hospitals. A general journal is given in the Working Papers. This piece concludes with thoughts regarding the COVID-19 pandemics effect on the immediate future of physician and APP compensation valuation. 1320a-7b. Office-based primary care has been significantly affected as offices were closed for a period of time and then had to adjust to telehealth and virtual visits.