Jacksonville Bar Health Law Section

Presentation for the Jacksonville Bar Health Law Section.

The Stark Law Update topics include the following:

  • "Stand in the shoes", which affects whether an arrangement with a physician is analyzed as a "direct" or "indirect" relationship under the Stark Law;
  • Revisions to the Stark Law physician recruitment regulatory exception, which has broadened the scope of allowable contractual arrangements between physician recruits and hospitals/federally qualified health centers;
  • Changes to "under arrangements" relationships between physicians and physician-owned entities and hospitals, which will necessitate the restructuring of many of these arrangements; and
  • Changes to CMS' interpretation of per click/percentage payment arrangements with physicians, which will necessitate the restructuring of certain lease arrangements, e.g., hourly or percentage equipment leasing arrangements.