Web-Based Educational Seminar
Web-Based Educational Seminar on New Stark Regulations
On March 26, 2004, the Centers for Medicare and Medicaid Services (“CMS”) published the second phase of the final Stark Law regulations (the “Phase II Rule”). Effective as of July 24, 2004, the Phase II Rule revises several existing exceptions and key definitions contained in the Phase I Rule. The Phase II Rule also creates several new exceptions.
Enforcement of Stark Law violations is likely to increase now that CMS has published the Phase II Rule. Health care providers and suppliers, including hospitals, must ensure that their financial relationships with certain physicians referring designated health services comply with a Stark Law exception. Failure to do so could result in potentially significant penalties.
Ice Miller conducted a web-based educational seminar on April 22, 2004 focusing on:
- Compensation Arrangements, including
- Permissible methods of calculating compensation, such as percentage-based, per-click, or hourly payment arrangements; and
- Appropriate productivity bonuses based on personally provided services or "incident to" services.
- Protected Physician Recruitment and Retention Practices.
- Changes to the In-Office Ancillary Exception, including revisions to key definitions.
- New Exceptions, including those for
- Professional courtesies;
- Intra-family referrals; and
- Temporary noncompliance.
Speakers were Gregory L. Pemberton, chair of Ice Miller's Health Care Group and Karen Ann P. Lloyd, partner in Ice Miller's Health Care Group.
Materials for download:
- PowerPoint presentation of the Web-based seminar contents
- Seminar supplemental materials
- Download a video/audio recording of the Web-based seminar (approx. 1 hour in length) (12.4 MB zip file)
