Complying With 2016 Stark Law Amendments and Possible Changes in the Horizon for 2017

The Centers for Medicare and Medicaid Services (CMS) published the most significant changes to the Stark law since 2008, which went into effect in 2016. The amendments established new exceptions and clarified existing exceptions and requirements.

The changes include exceptions related to recruitment for non-physician practitioners and certain timeshares and a broader fair market value exception. They also clarify retention payment regulations and provide guidance on the ownership and advertising requirements for physician-owned hospitals.

In Nov. 2016, CMS reissued its prohibition on certain unit-based rental arrangements with referring physicians, which goes into effect on Jan. 1, 2017. To ensure clients are in full compliance, counsel to healthcare facilities and providers must fully understand the amendments.

Listen as our authoritative panel examines the Stark law amendments and analyzes the impact of the changes. The panel will also address the changes that providers and their counsel should make to be in compliance with the new/revised requirements.

1. Stark law amendments
   1. New exceptions
   2. Clarifications
   3. Incident to services
2. Reissued rules restricting per-click arrangements
3. Impact of the changes
4. What providers and counsel need to do to ensure compliance

The panel will review these and other key issues:

• How do the amendments change the writing, term, holdover and signature requirements?
• What new exceptions were created under the Stark Law amendments?
• What must healthcare providers do now to ensure compliance with the Stark Law changes?