STARK BASIC TRAINING - The American Health Lawyers Association
STARK BASIC TRAINING - The American Health Lawyers Association
STARK BASIC TRAINING - The American Health Lawyers Association
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WHAT’S NOT A REFERRAL<br />
• Requests made by pathologists, radiologists,<br />
and radiation oncologists<br />
• Pursuant to a consultation<br />
• For their own services (see defn)<br />
• Furnished by them or under their<br />
supervision (or by/under supervision of<br />
physician in same group and of same<br />
specialty)<br />
21<br />
“REFERRING PHYSICIAN”<br />
• A “physician” who makes a referral<br />
• 1861(r) definition of physician applies<br />
• Does not include physician extenders or<br />
other nonphysicians<br />
• But see discussion of imputed referrals<br />
22<br />
11
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