Compliance: A Reprieve For Many Common Joint Ventures

Why This Topic Matters

It helps readers assess whether existing joint ventures and imaging-related arrangements may need review because of CMS rule changes affecting Medicare billing and Stark compliance.

Article Sections

1. CMS rulemaking on Stark joint ventures

   This section summarizes CMS activity in the 2008 fee schedule rulemaking and discusses proposed changes that were not finalized at that time. It also notes that additional regulation is expected later.

2. Imaging arrangements and the anti-markup change

   This section covers CMS’s new approach to certain imaging payment arrangements and how the change affects office-based and outside-office interpretation relationships. It also addresses the related Phase III Stark adjustments.

3. Common practice structures affected

   This section describes common shared-space and diagnostic equipment arrangements that may be affected by the evolving rules. It includes discussion of centralized building setups and similar physician leasing models.

4. Compliance uncertainty and practical impact

   This section highlights the ambiguity in the regulatory language and the uncertainty surrounding how practices should interpret the new requirements. It closes with the likely effect on existing arrangements that were previously considered permissible.