StarkCompliancePlus helps address the challenges that the federal physician self-referral or "Stark" law presents to physicians, hospitals, academic practices and other health care organizations, with an emphasis on the Stark law’s application to physician compensation systems.
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Stark II, Phase III The compliance minutia continues
On Sept. 5, 2007, the Centers for Medicare & Medicaid Services (CMS) published the long-awaited Phase III final rule to the federal physician self-referral or Stark law. Using another 500-plus pages of preamble and revised regulatory text, CMS addressed comments and questions, provided clarification and made several significant changes to the Phase II interim final rule published in 2004. CMS officials said the Phase III rule provided additional clarity and flexibility for physicians and health care providers. Unfortunately, despite CMS’ stated goal of providing “bright line” guidance, the changes and their relationship to other initiatives are likely to increase the complexity and confusion that goes hand in hand with the Stark law.
The new rule was not as sweeping and far-reaching as many observers expected. In Phase III, CMS declined to address some key themes that are clearly on the agency’s radar, including proposed amendments to address “under arrangement” ventures, “per click” leases and others that were proposed as part of the 2008 Medicare physician fee schedule (PFS) in July 2007. Those provisions were not addressed because of timing, not because CMS has had a change of heart. Given the attention that CMS has paid to those arrangements, it’s likely that new rules relating to those and other issues will be forthcoming as part of the 2008 PFS final rule or at a future date.
Read the exclusive analysis of the significant “tweaks” made by Phase III for StarkCompliancePlus subscribers.
Fall 2007 StarkCompliancePlus bulletin released
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