tci Medicare Compliance & Reimbursement - 2009 Issue 21
Get a New Lease on Stark Compliance: Target Variable Compensation Rental Arrangements
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Article Overview
This article reviews recent Stark law updates that affect physician, group, and hospital leasing arrangements tied to variable compensation. It is aimed at providers, compliance staff, and healthcare attorneys who need a high-level understanding of how the changes relate to equipment and space rentals, percentage-based compensation, and related federal compliance concerns.
Why This Topic Matters
The topic matters because leasing structures that were once common may no longer fit within Stark exceptions after the cited effective date. Providers need to recognize which general arrangement types are affected so they can assess compliance risk and avoid potentially problematic referral relationships.
Article Sections
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Variable rent arrangements and equipment leases
Introduces the general category of leasing arrangements affected by the Stark changes and discusses why certain variable compensation structures are now a compliance concern.
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What arrangements may still be permissible
Summarizes the article’s discussion of remaining lease structures and the need to consider related compliance requirements beyond Stark.
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Percentage-of-revenue arrangements
Covers the article’s discussion of compensation structures tied to revenue and the distinction between lease-related concerns and other service arrangements.
What You Will Learn
- The general categories of leasing and rental arrangements discussed in connection with Stark compliance
- How the article frames variable compensation issues in physician-hospital relationships
- The broader compliance topics that may accompany lease-based arrangements
- The types of rental structures the article identifies as needing review after the Stark changes
Who Should Read This
- Physician practices
- Hospitals
- Healthcare compliance professionals
- Healthcare attorneys
- Medical practice administrators
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