MORE STARK III CHANGES:

PHYSICIAN RECRUITMENT

There have been a number of definitional or technical changes to the physician recruitment exception.

·        The definition of the hospital’s geographic service area, which was previously the area composed of these contiguous zip codes from which the hospital drew 75% of its inpatients, has been tweaked to…

CMS ISSUES STARK ADVISORY OPINION PROHIBITING

 AMENDMENT OF RECRUITMENT AGREEMENT

On October 3, 2007, the Centers for Medicare and Medicaid Services (CMS) issued Advisory Opinion CMS – AO – 2007 – 01 denying permission to the hospital and physician to revise a physician recruitment agreement. The proposed amendment would have deleted and “excess receipts provision, which…

OIG ADVISORY OPINION 07-10 APPROVES CALL PAY

On September 27, 2007, the Office of the Inspector General of the Department of Health and Human Services posted OIG Advisory Opinion No. 07-10 which approves a tax exempt hospital proposal for compensating physicians for on call coverage. While acknowledging that on call compensation potentially creates considerable risk that…

STARK III REGULATIONS TEXT

CMS issued the revised Stark III Regulations to be effective as of December 4, 2007. The text of the regulations is accessible at the link below, and the Med Law Blog will publish a number of short posts over the next two months highlighting certain changes prior to that effective date.

The…