Tag Archives: Stark

CMS Announces New Stark Self-Referral Disclosure Protocol

  New – Medicare Self-Referral Disclosure Protocol CMS has published the self referral disclosre protocol required by ACA. Link and announcement below. Analysis will be posted next week. Section 6409(a) of the Affordable Care Act (ACA) ACA requires the Secretary of the Department of Health and Human Services, in cooperation with the Inspector General of … Continue Reading

CMS Position on Whole Hospital Physician Ownership Stark Exception

  Physician Self-Referral CMS proposes to implement changes enacted in ACA to the "whole hospital" and "rural provider" exceptions in the physician self-referral law that will prohibit their use by new physician-owned hospitals and limit the ability of existing physician-owned hospitals to expand their capacity. The deadline for physician investment and having a provider agreement … Continue Reading

October 1, 2009: Effective Date of New Stark Rules

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 … Continue Reading

OIG Advisory Opinion 09-05 Approves Physician On Call Compensation

The Office of Inspector General of the Department of Health and Human Services has issued Advisory Opinion No. 09-05, which states that the OIG will not impose sanctions regarding a proposed on call arrangement in which the hospital will compensate physicians for providing on call coverage for patients presenting to the hospital or emergency department. The … Continue Reading