STARK BASIC TRAINING - The American Health Lawyers Association

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• DMEPOS DHS • Parenteral and enteral nutrients, equipment, and supplies • Prosthetics, orthotics, and prosthetic devices and supplies • Home health services • Outpatient prescription drugs • Inpatient and outpatient hospital services • except lithotripsy! 27 GENERAL RULES • Code List is determinative • DHS bundled into a composite rate payment is not DHS • Exception: If the service package itself is listed in the statute as a DHS (e.g., inpatient hospital services) • DHS paid as stand-alone service is DHS • New Exception (eff. 1/1/08): radiology and drugs furnished in an ASC that qualify as “covered ancillary services” per 416.164(b). 28 14
RESOURCES • 1877(h)(6); 411.351 • Phase I (pp. 922-42) • Phase II (pp. 16099-16106) • Nuclear medicine, 70 FR at 70283 (11/21/05) • CY08 OPPS Final Rule, 72 FR 66851 (11/27/07) • Revising defns of DHS, outpatient Rxn drugs, radiology • PFS CPT/HCPCS Code List Updates 29 ENTITY (So many entities, so little time…) 30 15
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 and 12: WHAT’S NOT A REFERRAL • Request
Page 13: DESIGNATED HEALTH SERVICES (Not eve
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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