Beware:
Stark Reg Revamp Impacts Under Arrangement Services
Published on Fri Oct 09, 2009
The change is altering the payment and compliance landscape. In the Medicare and Medicaid compliance world, the fate of a healthcare provider often hinges on the interpretation of a single word like "reasonable" or "necessary" or "quality." And under the Stark law, a critical word is "entity," which, as of Oct. 1, has a broader impact on how healthcare providers can do business. In a nutshell: The Stark law forbids physicians from referring Medicare patients for designated health services (DHS) to an entity with which the physician or an immediate family member has a financial relationship -- unless there's a Stark exception. And the Stark regulations now define entity as covering "both the party performing the DHS, as well as the party billing for the DHS," says Nashville, Tenn. attorney Thomas Bartrum. The change affects so-called under-arrangement services, where a hospital or other healthcare provider enlists a third party to provide [...]