BarbriSFCourseDetails
  • videocam Live Webinar with Live Q&A
  • calendar_month April 9, 2026 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Health
  • schedule 90 minutes

Forming Physician Supergroups: Structural and Regulatory Challenges

Entity Structure, Governance, Reimbursement, Federal and State Stark Laws, Anti-Markup Rule

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About the Course

Introduction

This CLE course will provide a review of key legal issues involved in forming physician supergroups, including applicable laws and regulations, as well as business considerations. The panel will offer guidance on structuring practice management arrangements and selecting compensation models.

Description

Healthcare organizations are facing increased pressure to improve quality while cutting costs. Physicians are banding together to form supergroups to achieve scale to generate cost efficiencies. Physician consolidation can improve the group's negotiating position with payers and make the provision of ancillary services possible.

However, supergroup formation is not without its challenges. There are structural issues and regulatory hurdles to consider when creating supergroups. The parties should consider the type of entity to form, the impact on reimbursement, and Stark Law requirements.

Another consideration is the application of the Anti-Markup Rule, which prohibits a billing physician or supplier from marking up either the technical component or professional component of a diagnostic test ordered by the billing physician or supplier unless the performing physician shares a practice with the billing physician or supplier.

If the performing physician does not share a practice with the billing physician or supplier, then the rule applies; the healthcare provider/supplier cannot bill Medicare an amount that exceeds payment to the physician.

Listen as our authoritative panel examines the structural and regulatory challenges involved when forming physician supergroups, including Stark and Anti-Markup Rule compliance and the impact of ancillary services.

Presented By

Adria Warren
Partner
Foley & Lardner LLP

Ms. Warren is a healthcare M&A and regulatory lawyer with deep experience advising hospitals, providers, and healthcare enterprises on complex transactions, corporate, and regulatory compliance matters. Her experience includes mergers, acquisitions, joint ventures, and other affiliations and strategic transactions; forming provider groups, networks, and alliances; and advising on fraud and abuse and HIPAA compliance, employment, reporting and disclosure requirements, and marketing compliance.  Ms. Warren has over two decades of experience and brings a wealth of business and transactional experience to assist clients in the healthcare industry, including providers, private equity, medical device companies, life sciences companies, and healthcare IT companies. In addition, she counsels entrepreneurs and established companies on a wide range of day-to-day legal and business issues from starting-up through going public, including corporate governance issues, securities laws compliance, tax, and employment matters. 

Hannah E. Zaitlin
Partner
Foley & Lardner LLP

Ms. Zaitlin’s practice focuses on advising investors, health systems, physician groups, and health service providers across the health care continuum in mergers, acquisitions, divestitures, restructurings, joint ventures, and strategic affiliations. She is a partner in the firm’s Health Care Transactions and Health Care Regulatory Practices. Ms. Zaitlin has played a leading role in several transformational transactions for nonprofit health systems in recent years and has significant deal experience involving physician groups, physician practice management companies, post-acute care, ambulatory surgery centers, durable medical equipment (DME) providers, and telemedicine companies. She also works regularly with investors, entrepreneurs, and startup businesses in the digital health arena, particularly in the areas of telepsychiatry, behavioral health, and substance use disorder treatment. Ms. Zaitlin frequently advises on innovative business models, corporate structuring, and compliance matters involving telemedicine, digital health, remote patient monitoring, and virtual care.

Credit Information
  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, April 9, 2026

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Structural considerations in forming a supergroup 

A. Due diligence

B. Governance

C. Entity structure

D. Distribution of profits

II. Regulatory challenges 

A. Federal and state Stark laws

B. Federal Anti-Markup Rule

III. Best practices for forming physician supergroups


The panel will review these and other high priority issues:

  • What are the critical legal and business concerns for physicians considering forming a physician supergroup?
  • What considerations should healthcare counsel weigh when selecting the appropriate legal entity for the business?
  • What are the main regulatory hurdles under Stark with forming and operating a physician supergroup?