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April 04, 2024   

Stark Law Liability on the Rise: How to Spot Suspect Physician Compensation Arrangements

This Bulletin is brought to you by AHLA’s Fraud and Abuse Practice Group.
  • April 04, 2024
  • Mitchell Surface , Maynard Nexsen

A recent settlement agreement serves as a reminder that significant liability can still stem from a violation of the federal Physician Self-Referral Law (Stark law). In December 2023, Community Health Network Inc. (CHN), an Indianapolis-based integrated health care system, agreed to a $345 million settlement with the Department of Justice (DOJ) to resolve allegations under the False Claims Act related to employment compensation structures alleged to be above fair market value (FMV). The reminder, therefore, is that as hospitals continue to employ physicians, compensation arrangements must be carefully reviewed to ensure FMV so to provide evidence that such arrangements do not “take into account” the value or volume of referrals.


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