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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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Monday, December 4, 2023

Recorded event now available

or call 1-800-926-7926

This CLE course will guide healthcare counsel and compliance officers to what they need to know three years after the December 2020 changes to the Stark Law and Anti-kickback Statute regulations. The panel will discuss the evolving impact of the regulatory changes in the context of the recent ending of the COVID-19 Public Health Emergency and multiple other regulatory and legal developments since December 2020.


Listen as our authoritative panel discusses and addresses your questions regarding the evolving impact of the December 2020 Stark Law and Anti-kickback final rules, including the new definitions and clarifications. The panel will discuss what the changes currently mean for healthcare providers and others in the healthcare industry as we close out 2023 and head into 2024.



  1. Overview of the current state of legal requirements for healthcare provider compensation arrangements, including the evolving understanding of the Stark Law regulatory definitions and exceptions and Anti-Kickback Statute safe harbors introduced in 2020
  2. Evolving concepts of fair market value and “commercially reasonable” since the December 2020 Stark Law final rules
  3. The current rule for not taking into account volume or value of referrals under the Stark Law v. Federal Anti-kickback Statute and other laws


The panel will review these and other vital issues:

  • A detailed look at key 2020 Stark Law and Federal Anti-kickback Statute regulatory changes relating to healthcare provider compensation
  • Current perspectives on the "Big 3" requirements of fair market value, commercial reasonableness, and the prohibition on "taking into account" the volume or value of referrals and how these concepts are being, and in the future may be, utilized in enforcement actions
  • Steps healthcare advisers can take to ensure regulatory compliance when evaluating physician and other healthcare provider compensation in 2024 and beyond


Ferrari, Andrea
Andrea M. Ferrari, JD, MPH

Principal and General Counsel
Pinnacle Healthcare Consulting

Ms. Ferrari has more than 25 years of experience in the healthcare industry in various counsel, consulting and...  |  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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