Physician Compensation After Changes to the Stark Law and Antikickback Statute Regulations

FMV, Commercial Reasonableness, and Volume or Value Standards

Recording of a 90-minute CLE video webinar with Q&A

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Conducted on Tuesday, April 19, 2022

Recorded event now available

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Course Materials

This CLE course will guide healthcare counsel and compliance officers through the changes to the Stark and Anti-Kickback Statute regulations and the implications for physician compensation. The panel will discuss how the changes may impact the structure and evaluation of compensation for healthcare providers and others in the healthcare industry.


Listen as our authoritative panel addresses your questions regarding the impact of Final Rules for the Stark Law and Anti-Kickback Statute. The panel will discuss what the changes may mean for healthcare providers and others in the healthcare industry over the longer term.



  1. Overview of the current state of legal requirements for physician compensation arrangements, including new and revised Stark Law exceptions and Anti-Kickback Statute safe harbors
  2. Commercial reasonableness and FMV under the Final Rules
  3. The rule for not taking into account volume or value of referrals under the Stark Law Final Rule


The panel will review these and other vital issues:

  • Stark Law changes relating to physician compensation
  • Steps healthcare advisers can take to ensure regulatory compliance when evaluating physician compensation
  • Impact of the changes on healthcare providers and others in the healthcare industry
  • New bright-line guidance on Stark's "Big 3" requirements of fair market value, commercial reasonableness, and the prohibition on "taking into account" the volume or value of a physician's referrals


Ferrari, Andrea
Andrea M. Ferrari, JD, MPH
Former Partner

Ms. Ferrari focuses on physician payments related to hospital-physician alignment and efficiency improvement...  |  Read More

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

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