CMS has released a 516-page draft of the long-awaited FINAL Stark Phase III regulations. The regulations, which were published in the Federal Register on September 5, may well prove to be as chilling to hospitals and physicians as Heather O'Rourke's famous tagline in "Poltergeist" was to moviegoers. Among other things, the new regulations provide for:
- Elimination of the fair market value hourly rate safe harbor
- A "stand in the shoes" provision attributing group practice financial arrangements to physicians in the group
- New rules for physician recruitment in rural areas
- Clarification about "non-monetary" benefits to physicians (e.g. is it still OK to pay for travel?)
Horty Springer attorneys Dan Mulholland, Henry Casale and Ian Donaldson present this audio recording andl review the changes to current rules, clarification of existing rules, and suggestions for changes that were rejected by the government.
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