Are the Stark law compensation exceptions for medical staff incidental benefits and nonmonetary compensation interrelated, or are they mutually exclusive? Said another way, does a DHS entity need to add up the value of medical staff benefits provided to a physician that are protected under the Stark law medical staff incidental benefits compensation section and aggregate this with benefits provided to that same physician that meet the nonmonetary compensation exception, to ensure that the nonmonetary compensation exception cap is not exceeded? Or are they two separate and distinct categories?
Note the non-monetary compensation exception and incidental medical staff benefits exception are not interrelated. The tracking for the non-monetary compensation is separate from the incidental medical staff benefits exception. If a benefit to a physician (e.g. lab coat or modest food/beverages in physician lounge) fits within the incidental medical staff benefit exception, it does not have to be tracked as non-monetary compensation.