New Stark Regulations and Impact on Fair Market Value/Commercial Reasonableness

Bob Wade, Partner, Barnes & Thornburg LLP. Alex Krouse, Attorney, Parkview Health.

April 6, 2021

  • What is fair market value

  • What is the commercial reasonableness standard based upon the Final Rules

  • Application of benchmark data to physician referral sources

  • "Best Practices" for documenting and reviewing compensation arrangements with referral sources, specifically focusing on physician referral sources

  • Subjective factors/business justifications to support compensation arrangements with referring physicians

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The Health Care Compliance Association (HCCA), is a 501(c)6 non-profit, member-based professional association. HCCA was established in 1996 and is headquartered in Minneapolis, MN. We provide training, certification, and other resources to over 10,000 members. Our members include compliance officers and staff from a wide range of organizations, including hospitals, research facilities, clinics and technology service providers.

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