Stark Law Changes: Complying With the 2009 Inpatient Prospective Payment System Final Rule

Mastering the New Complexities of Physician Self-Referral

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

Conducted on Wednesday, July 1, 2009

Course Materials

This seminar will examine the 2009 IPPS Final Rule changes to the Stark Law  regulation and outline compliance strategies for healthcare attorneys in the current regulatory environment.


Last year, the Centers for Medicare and Medicaid Services issued the FY 2009 Inpatient Prospective Payment System (IPPS) Final Rule, effective Oct. 1, 2008. The 2009 IPPS makes several important changes to the Stark Law regulations on physician self-referral.

The new revisions finalize earlier proposals related to the “stand in the shoes” provisions and period of disallowance, among others. The changes will bring more transparency to referral activity and physician financial relationships.

Attorneys advising healthcare facilities and providers must fully understand the revisions to ensure clients are in full compliance.

Listen as our panel of health law attorneys explains the key Stark Law changes addressed in the 2009 IPPS Final Rule and offers best practices for complying with the final rules.



  1. FY 2009 notice of proposed rulemaking changes finalized in final rule
    1. Period of disallowance
    2. “Stand in the shoes” provisions
  2. CY 2008 Medicare physician fee schedule changes finalized in final rule
    1. Revised definition of entity (services furnished under arrangements)
    2. Per click leases
    3. Percentage compensation arrangements
    4. Alternative method for compliance
    5. Obstetrical malpractice subsidies
    6. Burden of proof
    7. Retirement plans
  3. Best practices for complying with the new rules


The panel will review these and other key questions:

  • How does the 2009 IPPS Final Rule impact physician self-referral?
  • What are the practical impacts of the finalized "stand in the shoes" provisions?
  • What must healthcare providers do now to ensure compliance with the new rules?


Donald H. Romano
Donald H. Romano
Arent Fox

He focuses on physician self-referral (Stark) anti-kickback matters and Medicare reimbursement issues affecting...  |  Read More

Ann DesRuisseaux
Ann DesRuisseaux

She previously served as Assistant General Counsel with DaVita; Senior Compliance Counsel and Acting Chief Compliance...  |  Read More

Paul F. Danello
Paul F. Danello

Baker & Daniels

He is head of the firm's Washington, D.C. Health Care Practice. He has been involved in healthcare law on an...  |  Read More

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