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Stark Compliance Audits in Hospital-Physician Arrangements: Mitigating Provider Liability

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

Recording of a 90-minute CLE 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 Tuesday, March 31, 2020

Recorded event now available

or call 1-800-926-7926

This CLE course will guide counsel to healthcare providers on auditing hospital-physician arrangements to ensure compliance with the Stark Law. The panel will offer best practices for mitigating the risks in physician arrangements and avoiding violations.


Healthcare reform invigorated the government's focus on healthcare fraud, including enforcement of the Stark Law. Improper design and implementation of hospital-physician arrangements can result in penalties, denial of payments, and exclusion from federal healthcare programs.

Proposed new Stark Law exceptions for "value-based arrangements"--along with other changes to Stark Law--will apply broadly to compensation arrangements between physicians and hospitals, other healthcare providers, and qualifying payors. Healthcare counsel must ensure compliance.

Internally auditing hospital-physician arrangements is crucial to ensuring Stark compliance. Our panel will offer best practices to counsel for healthcare providers to minimize liability exposure and penalties, including conducting compliance audits, instituting policies, and establishing ongoing monitoring and reviews.

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 importance of compliance audits
    1. Risks inherent in hospital-physician transactions
    2. 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. Expired contracts
    2. Expired leases
    3. Absence of signed agreements
    4. Lack of FMV assessment
    5. Agreement is not commercially reasonable absent 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 vital questions:

  • What are the inherent risks in hospital-physician arrangements for Stark violations?
  • What issues do audits often flag--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?


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

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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