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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“SERVICE-BASED”<br />
EXCEPTIONS<br />
• Physician Services<br />
• In-Office Ancillary Services<br />
• Supervision, location & billing requirements<br />
• Academic Medical Centers (AMCs)<br />
• Prepaid plans (managed care services)<br />
• Intra-family rural referrals<br />
• Others<br />
53<br />
• Many exceptions<br />
COMPENSATION<br />
EXCEPTIONS<br />
• Fair market value is key<br />
• Multiple exceptions may apply<br />
• In general, provider can choose which of<br />
several potentially applicable exceptions to<br />
satisfy (the “any exception will do” rule)<br />
54<br />
27
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