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 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.
- A brief overview of the importance of compliance audits
- 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
- Expired contracts
- Expired leases
- Absence of signed agreements
- Lack of FMV assessment
- Agreement is not commercially reasonable absent 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 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?
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
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