STARK BASIC TRAINING - The American Health Lawyers Association

GROUP PRACTICE CRITERIA
• Share of profits will not be directly related to
volume or value of referrals if one of the
following conditions is met:
• Profits divided per capita (i.e., equal share per
physician in group);
• DHS revenues are distributed in the same manner
as non-DHS revenues from any federal health care
program or private payor; or
• DHS revenues for group practice is less than 5% of
group practices’ total revenue and those revenues
allocated to each physician in the group is 5% or
less of each physician’s total compensation from the
group
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GROUP PRACTICE CRITERIA
Permitted:
Patient
$
GROUP PRACTICE
DHS $ Pooled
%of $
%of $
%of $
DR.
DR.
DR.
Distribution of Profit from DHS
Should Reflect Pooling
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