Additionally, the huge verdicts being handed down for improper compensation arrangements in violation of the Stark Law and the Federal Claims Act and an increasingly aggressive enforcement climate focused on fair market value, commercial reasonableness, and not taking into account the value or volume of referrals, make it important that a health care attorney well versed in regulatory compliance matters, including Stark and related ancillary revenue-sharing issues, should also be involved in structuring any physician compensation package.
Explore This IssueDecember 2013
Steven M. Harris, Esq., is a nationally recognized health care attorney and a member of the law firm McDonald Hopkins, LLC. He may be reached at email@example.com.
Reprinted with permission from the American College of Rheumatology.