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STARK BASIC TRAINING - The American Health Lawyers Association

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THREE QUESTIONS<br />

1. Is there a referral from a physician for a<br />

designated health service? If so…<br />

2. Does the physician (or an immediate family<br />

member) have a financial relationship with the<br />

entity providing the DHS service? If so…<br />

3. Does the financial relationship fit in an<br />

exception?<br />

If not, there’s a violation<br />

13<br />

KEY CONCEPTS<br />

• Physician referrals<br />

• Designated health services (DHS)<br />

• Entity<br />

• Financial relationships<br />

• Exceptions<br />

14<br />

7

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