DME: Beware Of Shared Employees Under Stark II

Why This Topic Matters

Stark-related changes can affect how DME suppliers and physicians structure relationships, share employees, and report services tied to Medicare. Understanding the scope of the article helps readers identify compliance-sensitive arrangements and determine whether the discussed guidance is relevant to their operations.

Article Sections

1. Stark II enforcement and DME business practices

   Introduces the article’s focus on federal enforcement activity and how it may affect durable medical equipment suppliers and physician referral relationships.

2. Shared employees and supply closet arrangements

   Discusses a physician-office supply closet scenario involving shared personnel and the compliance concerns raised by the arrangement.

3. In-office ancillary services exception

   Summarizes CMS guidance on the in-office ancillary services exception and the types of items addressed in the discussion.

4. Codes

   Notes CMS commentary on identifying items considered durable medical equipment, supplier reference sources, and the role of coding in Stark-related review.

5. Drugs

   Mentions future rulemaking concerns related to prescription drug definitions in the Stark context.

6. Physicians furnishing DME

   Covers CMS clarification regarding physicians directly furnishing equipment they prescribe and related supplier-number considerations.

7. Pulse oximetry

   Addresses the article’s discussion of a specific service and its status under Stark.