Articles and Blogs

Historically, health care entities looking to avoid potential violations under the Federal Stark Law (“Stark”) have not turned to the Payments by a Physician exception at 42 C.F.R. § 411.357(i) to protect their operations. A review of the exception’s history, however, combined with recent experience with pending submissions to the Centers for Medicare &... READ MORE

Under the federal Stark Law, hospitals, physician groups, labs and other provider entities may provide non-monetary (i.e., non-cash or cash equivalent) compensation to physicians up to an aggregate amount of $519 for calendar year 2025. The dollar limit for “medical staff incidental benefits” provided by a hospital to a member of its medical staff... READ MORE

Under the federal Stark Law, hospitals, physician groups, labs and other provider entities may provide non-monetary (i.e., non-cash or cash equivalent) compensation to physicians up to an aggregate amount of $489 for calendar year 2023. The dollar limit for “medical staff incidental benefits” provided by a hospital to a member of its medical staff... READ MORE

Under the federal Stark Law, hospitals, physician groups and other provider entities may provide non-monetary (i.e., non-cash or cash equivalent) compensation to physicians up to an aggregate amount of $452 for calendar year 2022. The dollar limit for “medical staff incidental benefits” provided by a hospital to a member of its medical staff (e.g.,... READ MORE

In December 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued long-awaited final rules revising the Stark Law regulatory framework and updating the 2021 Medicare Physician Fee Schedule (“MPFS”). Though many health care organizations considered both updated regulatory frameworks when establishing their physician compensation programs for 2021, stakeholders in the industry continue to... READ MORE

Under the federal Stark Law, hospitals may provide non-monetary compensation to physicians up to an aggregate amount of $429 for calendar year 2021. The dollar limit for “medical staff incidental benefits” (e.g., meals, parking and other items or incidental services that are used on the hospital’s campus) is less than $37 per occurrence. Other... READ MORE

On December 1, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (“Final Rule”) that imposes several modifications to the Medicare Physician Fee Schedule (“MPFS”) for Calendar Year (“CY”) 2021. Notably, the Final Rule will materially increase the Work Relative Value Units (“wRVUs”) that are allocated to several common evaluation... READ MORE

The government continues to implement payment reforms and to lay the groundwork for the continuing shift in health care from a volume-based “fee-for-service” model to a value-based system that incentivizes outcomes and reductions in cost. Below we’ve outlined some immediate steps that health care organizations can take now to incorporate quality, value and cost... READ MORE