This is just a reminder of the effective date for certain new Stark Rules:
1. CMS prohibits percentage formulae conjunction with space on equipment leases, fair market value exception transactions and indirect compensation effective October 1, 2009.
2. Per click leases are prohibited effective October 1, 2009.
3. "Under arrangement" relationships have been changed because the definition of "entity" will, as of October 1, 2009 include both the billing provider and the provider who actually performed the service. Therefore, since the "in-office ancillary service" exception would not apply, these arrangements may no longer comply with existing Stark exceptions.