STARK BASIC TRAINING - The American Health Lawyers Association

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TIPS: • Can have multiple referring physicians for the same DHS • Do a separate 3-Question Analysis for each physician’s referrals 23 • 1877(h)(5) • 411.351 Definitions RESOURCES • “Physician” • “Referral” • “Referring Physician” • Phase I Preamble (2001), pp. 871-75 • Phase II Preamble (2004), pp. 16063-66 • Phase III Preamble (2007), pp. 51019-21 24 12
DESIGNATED HEALTH SERVICES (Not everything about Stark is complicated ….) 25 DHS • Clinical laboratory* • Physical therapy* • Occupational therapy* • Speech-language pathology* • Radiology and other imaging services* • Radiation therapy services and supplies* * Defined by CPT/HCPCS code 26 13
Page 1 and 2: STARK BASIC TRAINING Health Care Co
Page 3 and 4: THE SOLUTION: MULTIPLE STATUTES •
Page 5 and 6: WHAT’S NOT PROHIBITED • Physici
Page 7 and 8: THREE QUESTIONS 1. Is there a refer
Page 9 and 10: IMPUTED REFERRALS • Consulting ph
Page 11: WHAT’S NOT A REFERRAL • Request
Page 15 and 16: RESOURCES • 1877(h)(6); 411.351
Page 17 and 18: ENTITY • Multiple DHS entities ca
Page 19 and 20: DIRECT DOCTOR DHS ENTITY (No interv
Page 21 and 22: ICA EXCEPTION • Compensation must
Page 23 and 24: “STAND IN THE SHOES” Physician
Page 25 and 26: RESOURCES • 1877(a)(2), (h)(1)
Page 27 and 28: “SERVICE-BASED” EXCEPTIONS •
Page 29 and 30: FMV RESOURCES • Phase I (pp. 944-
Page 31 and 32: GROUP PRACTICE CRITERIA • Group p
Page 33 and 34: GROUP PRACTICE CRITERIA • Share o
Page 35 and 36: 69 IN-OFFICE ANCILLARY SERVICES EXC
Page 37 and 38: IOAS EXCEPTION Where Are Services P
Page 39 and 40: IOAS EXCEPTION How Are Services Bil
Page 41 and 42: RECRUITMENT • Payments made to in
Page 43 and 44: PSA EXCEPTION • Arrangement is se
Page 45 and 46: RENTAL EXCEPTIONS • Lease is in w
Page 47 and 48: EMPLOYMENT EXCEPTION • Employment
Page 49 and 50: Non-Monetary Compensation Exception
Page 51 and 52: NON-MONETARY COMPENSATION EXCEPTION
Page 53 and 54: MEDICAL STAFF INCIDENTAL BENEFITS E
Page 55 and 56: TIPS • Always draw a diagram •

STARK BASIC TRAINING - The American Health Lawyers Association

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