While the Stark Law blanket waiver published March 30, 2020, (effective back to March 1) provides healthcare organizations greater flexibility in developing financial arrangements with referring physicians, it is important to maintain sufficient documentation as a best practice to meet the record requirements under the blanker waiver.
PYA’s Stark Law Blanket Waiver Documentation Checklist may provide sufficient record for maintaining appropriate physician resources for coverage and care provision during the COVID-19 pandemic. However, depending on a healthcare organization’s specific facts and circumstances, other documentation may be required.
As such, PYA has developed the following compensation documentation form, which may serve to help support an appropriate record regarding the provision of COVID-19-related physician services. This form can be completed to support any necessary changes to physician compensation and contractual duties during the COVID-19 public health emergency (PHE).
If you have questions related to the appropriate documentation of the provision of COVID-19-related physician services, or would like additional COVID-19 guidance, visit PYA’s COVID-19 hub, or contact one of our PYA executives below at (800) 270-9629.