Fast Break: Stark Lessons II – Hospital-Physician Arrangements

The Stark Law applies to almost every hospital-physician arrangement. Whether a hospital wants to engage a physician to serve as a medical director or provide call coverage, the Stark Law's prohibition on physician self-referrals will likely apply to the relationship. Noncompliance with the Stark Law can be costly for hospitals. Further, noncompliance can lead to False Claims Act liability. Hospitals should be prepared to identify physician arrangements subject to the Stark Law and how to structure the relationship to be compliant.

In Part II of our Stark Law Fast Break, we will discuss how the Stark Law impacts hospital-physician arrangements and explore potential solutions to the challenges.

Topics will include:

• What is the Stark Law and what kind of hospital-arrangements does it apply to? 
• What kind of hospital-arrangements are not subject to the Stark Law? 
• Stacking physician compensation—is it permitted? 
• What does enforcement of Stark Law violations look like for hospitals, and what are the ramifications for noncompliance?