ACI National Forum on Clinical Integration: Stark Laws

Hilton Washington Embassy Row
Washington, DC

The National Forum on Clinical Integration guides attendees in navigating the complexities of structuring and implementing Accounting Care Organizations and other integrated health care models in the wake of landmark Health Care Reform legislation.  The Patient Protection and Affordable Care Act (PPACA) expressly creates specific measures to curb, transform, and reduce spending while increasing quality of care through the introduction of ACO pilot programs that will have a tremendous impact on the legal and compliant structure, organization, and implementation of integrated care and health care delivery systems.  

On November 16, David Matyas, Member of the Firm, will copresent on Stark Laws.  Topics include:

  • Identifying Stark landmines for forming ACOs and integrated models with outside investors
  • Anticipating a Stark waiver for PPACA ACOs in the absence of safe harbors
  • Using existing Stark exceptions stratigically
  • Understanding the interplay and distinction between strict liability Stark analysis and antitrust enforcement challenges
    - intent
    - market power and establishing Fair Market Value
    - exclusivity contracts
  • Implementing PPACA and evolving Stark guidance
    - in-office ancillary services
    - rural hospital exception
    - limitations on expansion
    - Constitutional challenges related to PHOs
  • Development of the Self-Referral Disclosure Protocol (SDRP)

For more information and to register, visit