In the 2022 Medicare Physician Fee Schedule Final Rule (2022 MPFS), the Centers for Medicare & Medicaid Services (CMS) clarified the definition of indirect compensation arrangements and its guidance regarding personal productivity. Together, CMS’ Modernizing and Clarifying the Physician Self-Referral Regulations, effective January 19, 2021, and the 2022 MPFS, effective January 1, 2022, shine a new light on physician compensation models involving work relative value unit (wRVU) productivity. The revisions within this guidance require a more careful look at whether physician compensation is fair market value, is commercially reasonable, and meets the volume or value/other business generated requirements under the Stark Law.
PYA Principal Angie Caldwell joined Foley & Lardner Partner Jana Kolarik for a virtual discussion and Q&A as part of the Let’s Talk Compliance series. The event was held on June 9, 2022.
For more information on the regulatory changes and their impact on physician compensation and compliance, read this new Bloomberg Law article authored by Angie and Jana.
If you would like additional guidance related to physician compensation strategies and valuation, or for assistance with any matter related to valuation, compliance, or strategy and integration, one of our executive contacts would be happy to assist. You may email them below, or call (800) 270-9629.