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Stark II Final Regulations: Hot Issues for Physician Practices

Stark II Final Regulations: Hot Issues for Physician Practices


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by Robert Falk, Esq., and Anne Hance, Esq.
The Stark law, first passed in 1989 and repeatedly expanded and clarified since then, has long created questions for group practices. Its primary intent is to prohibit physician referrals to entities in which the physician has a financial interest, but the details have proven confusing. The Stark law?s Phase II regulations, as put forth by the Centers for Medicare and Medicaid Services, went into effect in July and attempt to offer further clarification. In this article the authors explain some of the complexities of this most recent set of Stark law regulations, especially as they apply to smaller, multi-specialty practices.