Auditing Hospital-Physician Arrangements Under the New Stark Rules: Mitigating Provider Liability

Implementing Monitoring Processes to Avoid Penalties, Denial of Payment, and CMS Program Exclusion

A live 90-minute CLE video webinar with interactive Q&A

Wednesday, January 19, 2022

1:00pm-2:30pm EST, 10:00am-11:30am PST

Early Registration Discount Deadline, Friday, December 17, 2021

or call 1-800-926-7926

This CLE course will guide counsel to health care providers on auditing physician arrangements to ensure compliance with the new Stark Law regulations. The panel will offer best practices for mitigating risks and avoiding violations.


Healthcare reform has invigorated the government's focus on healthcare fraud and abuse, including enforcement under the Stark Law. Improper design and implementation of physician arrangements can result in penalties, denial of payments, and exclusion from federal healthcare programs. The panel will discuss best practices for healthcare provider counsel to minimize liability, exposure, and penalties, including conducting compliance audits, instituting policies and processes, and establishing ongoing monitoring and reviews.

Our panel will also discuss new the new Stark regulatory changes that went into effect in 2021, lessons learned from trenches, the new value-based framework, compliance and implementation considerations, and potential pitfalls.

Listen as our panel of healthcare attorneys and advisers discusses the auditing process and examines the issues that arise in audits and the resolutions to those issues. The panel will offer their perspectives and experiences to mitigate the risks in physician arrangements and to avoid Stark violations.



  1. A brief overview of the Stark Law
    1. Stark Law Overview
    2. Recent changes to the Stark regulations
    3. New exceptions
    4. The “Big 3” compliance standards (fair market value, commercial reasonableness, the volume/value standard)
    5. The value-based framework
    6. Risks inherent in hospital-physician transactions
    7. Sanctions for lack of compliance: penalties, denial of payments, exclusion from Medicare and Medicaid participation
  2. Process of auditing
    1. Audit priorities
    2. Fact gathering
  3. Common issues that arise in audits and resolutions to those issues
    1. Lack of a writing
    2. Late signatures
    3. Documentation of FMV and commercial reasonableness
    4. Compensation models that “take into account” referrals
  4. Best practices for mitigating risks in physician arrangements and avoiding violations
    1. Policies and procedures
    2. Ongoing monitoring
    3. Post-payment reviews


The panel will review these and other key issues:

  • What are the inherent risks in hospital-physician arrangements for Stark violations?
  • How should counsel and providers determine and document compliance with the “Big 3 compliance standards?
  • What issues are often flagged in audits, and what steps can counsel take to resolve those issues?
  • What practices can counsel and providers employ to reduce the risks of compliance violations under Stark?
  • How will the new Stark Law changes impact how healthcare providers audit their hospital-physician arrangements?


Wolfe, Joseph
Joseph N. Wolfe

Hall Render Killian Heath & Lyman

Mr. Wolfe provides advice and counsel to many of the nation's largest health systems, hospitals and medical groups...  |  Read More

Carty, Allison
Allison Carty, JD, MBA

Pinnacle Healthcare Consulting

Mr. Carty joined Pinnacle in late 2015 as a Director of Compensation Valuation following nearly a decade of experience...  |  Read More

Attend on January 19

Early Discount (through 12/17/21)

Cannot Attend January 19?

Early Discount (through 12/17/21)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video