Structuring and Auditing Non-Physician Practitioner Arrangements Under the New Stark Rules

Event Information
Product Format
Prerecorded Event
60 minutes
Product Description

Stark Law Changes for NPPs – Regulatory Requirements, Key Provisions, Potential Pitfalls and More!

CMS has finalized a number of significant changes to the Stark Law, including a new Stark exception that allows hospitals to provide financial support to physician practices that employ or contract with non-physician practitioners ("NPPs").

As health care organizations and physicians develop NPP arrangements, they must manage their compliance and enterprise risk by ensuring their arrangements are defensible under the Stark Law. Prior to moving forward with any NPP arrangements, the parties should carefully evaluate whether the proposed structure and financial terms support compliance with Stark’s technical requirements and key tenets of defensibility so they will be prepared to mount a defense in the event the lease is ever challenged.

Join this session by expert speaker Joseph Wolfe as he provides an overview of the Stark Law, including its most recent changes. He will also discuss best practices for negotiating and drafting NPP arrangements on behalf of health systems, hospitals, medical groups and physician practices. The webinar will focus on the regulatory requirements, key provisions, valuation considerations and potential pitfalls that should be avoided.

Session Highlights

  • Overview of Stark Law
  • Critical components of Stark-compliant NPP arrangements
  • Best practices for NPP arrangements and the related financial terms
  • Best practices for auditing these arrangements
  • Processes for documenting fair market value and commercial reasonableness
  • Best practices for auditing existing NPP arrangements and potential pitfalls

 Session Agenda

  • Introductory concepts
    • The enforcement climate
    • Considerations for managing risk
    • New and recurring issues
  • Applicable regulatory standards overview
    • The anti-kickback and safe harbors
    • The Stark Law framework
    • Stark’s key tenets of defensibility
    • The Stark exceptions
      • Fair market value (FMV) defined
      • The taken into account (TIA) prohibition
      • Commercial reasonableness
  • Requirements of Stark employment, recruitment and assistance to compensate NPP exceptions
    • Employment exception
    • Recruitment exception
    • Assistance to compensate an NPP exception
  • 2016 Stark Law Changes
  • Reasons to audit recruitment/ NPP assistance arrangements
    • Why conduct a Stark audit
    • Disproportionate penalties
    • Internal controls and processes
  • The auditing process
  • Strategies for mitigating risk

Who should attend

  • In-House counsel
  • Healthcare compliance officers
  • Healthcare human resources
  • Healthcare CFOs
  • Healthcare executives

At the Q&A session following the live event, ask a question and get advice unique to your situation, directly from our expert speaker.

Order Below or Call 1-844-384-4744 Today

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About Our Speaker

Joseph Wolfe - Stark Law Expert


Joseph Wolfe is a partner with Hall, Render, Killian, Heath & Lyman, P.C., the largest health care focused law firm in the country, now with offices nationwide. Hall Render's attorneys provide advice and counsel to many of the nation's largest health systems, hospitals and medical groups on a variety of health care issues. Mr. Wolfe regularly counsels clients on a national basis regarding compliance-focused physician compensation strategies. He...   More Info
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