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Published August 15, 2022

“Physician Compensation Arrangements After Stark Law Changes”

Bloomberg Law recently published an article co-authored by PYA Principal Angie Caldwell and Jana Kolarik, a partner at Foley & Lardner, in its August edition. The article, “Physician Compensation Arrangements After Stark Law Changes,” is the second part of an article published by Bloomberg in June 2022. The latest article analyzes the previous compliance takeaways, including fair market value (FMV) and commercial reasonableness (CR) considerations. Using the same example from the first article, the authors focus on the related FMV and CR analyses. The article also recommends that providers continually review physician arrangements in order to maintain compliance.

Article Excerpt

Such revisions may impact current financial arrangements with physicians, and especially the FMV and CR analyses supporting them. A thorough Stark Law exception analysis of physician arrangements, including FMV and CR determinations, is not evergreen and requires continued focus and comprehensive review.

Find the full article here. Find Part One of the article here.

Physician compensation and new Stark Law regulations were also the focus of Angie and Jana’s recent Let’s Talk Compliance virtual discussion. Find the on-demand recording and slides here.

If you would like additional guidance related to the Stark Law or physician compensation strategies and valuation, or for assistance with any matter related to valuation, compliance, or strategy and transactions, one of our executive contacts would be happy to assist. You may email them below, or call (800) 270-9629.

Executive Contacts

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