tci Medicare Compliance & Reimbursement - 2009 Issue 21

Beware: Stark Reg Revamp Impacts Under Arrangement Services

The change is altering the payment and compliance landscape. In the Medicare and Medicaid compliance world, the fate of a healthcare provider often hinges on the interpretation of a single word like "reasonable" or "necessary" or "quality." And under the Stark law, a critical word is "entity," which, as of Oct. 1, has a broader impact on how healthcare providers can do business.In a nutshell: The Stark law forbids physicians from referring Medicare patients for designated health services (DHS) to an entity with which the physician or an immediate family member has a financial relationship --...

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