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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“STAND IN THE SHOES”<br />
Physician<br />
Owners<br />
(aka, when an unbroken<br />
chain of 3 is a direct comp<br />
arrangement)<br />
DHS ENTITY<br />
Physician<br />
Group<br />
45<br />
“STAND IN THE SHOES”<br />
• Current Rule (since 10/1/08):<br />
• Physician SITS of his physician organization<br />
(PO) if he has an ownership/investment interest<br />
in the PO<br />
• Non-owners and titular owners may elect to<br />
SITS<br />
• Old Rule: All physicians SITS of their PO<br />
• Really Old Rule: Nobody SITS at all<br />
46<br />
23
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