In this Presentation:

*Stark Act

*Designated Health Services

*New CMS Stark Regulations

*Definition of DHS Entity

*Physician Owners “Stand in the Shoes” of Their Physician Organizations in Relation to DHS Entities

*Prohibition Against Unit-of-Service or “Per Click” Payments

*Prohibition Against Percentage-Based Compensation for Rental of Office Space and Equipment

*“Set in Advance” and Amendments to Agreements

*The Anti-Kickback Statute

*Private Inurement

*Private Benefit

*Physician Recruitment and Retention – General Rule Under Stark

*Physician Recruitment and Retention – New, Revised and Additional Standards

*Physician Recruitment and Retention –

New, Revised and Additional Standards

*Other Changes Under Stark II, Phase III

*Physician Recruitment – IRS Standards

*Call Compensation: Two OIG Advisory Opinions

*09-05 Does Not Trump 07-10

*Lost Opportunity Payments

*A Few Words on FMV

*Background on 07-10