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
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.
- A brief overview of the Stark Law
- Stark Law Overview
- Recent changes to the Stark regulations
- New exceptions
- The “Big 3” compliance standards (fair market value, commercial reasonableness, the volume/value standard)
- The value-based framework
- Risks inherent in hospital-physician transactions
- Sanctions for lack of compliance: penalties, denial of payments, exclusion from Medicare and Medicaid participation
- Process of auditing
- Audit priorities
- Fact gathering
- Common issues that arise in audits and resolutions to those issues
- Lack of a writing
- Late signatures
- Documentation of FMV and commercial reasonableness
- Compensation models that “take into account” referrals
- Best practices for mitigating risks in physician arrangements and avoiding violations
- Policies and procedures
- Ongoing monitoring
- 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?
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
Mr. Wolfe provides advice and counsel to many of the nation's largest health systems, hospitals and medical groups on a variety of health care issues. He regularly counsels clients on a national basis regarding compliance-focused physician compensation strategies. Mr. Wolfe is a frequent speaker on issues related to the physician self-referral statute (Stark Law), hospital-physician transactions, physician compensation and health care fair market value issues. Before attending law school at the University of Wisconsin, he served as a combat engineer in the United States Army.Close
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
Mr. Carty joined Pinnacle in late 2015 as a Director of Compensation Valuation following nearly a decade of experience focused on physician-hospital arrangements. She focuses on physician compensation and related plan structuring and compliance. In addition to valuation work, Ms. Carty maintains an interest in health care regulatory matters pertaining to physician-hospital transactions, including requirements associated with commercial reasonableness.Close
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.