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"The Stark Law: A proactive approach to audit and compliance"

By Sarah E. Coyne and Jon R. Kammerzelt
New Perspectives

Below is an excerpt:

The Stark Law is one of the most counterintuitive and difficult healthcare laws in existence. Healthcare entities and physicians are often embroiled in arrangements that are noncompliant through innocent and well-intended business efforts. Here are the basics of a proactive internal audit mechanism to help healthcare providers identify and remediate noncompliant arrangements as early as possible, in order to mitigate the potentially significant financial damages.

The basic prohibition under the Stark Law is that physicians may not make referrals of patients for certain designated health services (DHS) payable under a federal health program to an entity with which the physician has a financial relationship (such as a hospital), unless an exception applies.


Originally published in New Perspectives, September 1, 2017

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