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Published March 17, 2021

PYA Principal Quoted in HCCA Article on Stark Regulations and the Impact of Commercial Reasonableness Definition on Medical Directorships

PYA Principal Lyle Oelrich is quoted in a recently published Report on Medicare Compliance article about the Centers for Medicare & Medicaid Services’ (CMS) new definition of commercial reasonableness in the Stark regulations. The article, “New Stark Regulation May Spark Reviews of Medical Directorships,” explains that with this new definition, hospitals should look into their medical director agreements, ensuring each has a legitimate business purpose and there are no duplicates. While some medical director agreements are in place to meet federal or state regulatory requirements, others may require a more analytical review.

Article Excerpt:

In these situations, medical directorships are potentially duplicative, and [Lyle Oelrich] suggests hospitals evaluate whether some administrative services can be consolidated or restructured. “However, ultimately, each individual medical directorship may be supportable as any formal analysis of medical directorship need is facts and circumstances specific,” he said.

Read the full article on the Health Care Compliance Association’s (HCCA) COSMOS, an online platform for easy access to the latest compliance information.

If you would like more information on new Stark regulations, commercial reasonableness, and the effect on medical directorships, or for assistance with any matter involving valuation, compliance, or strategy and integration, contact one of our PYA executives below at (800) 270-9629.

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