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December 10, 2012

New Settlement Under the Stark Self-Referral Disclosure Protocol

Another hospital decides to self-disclose possible Stark violations. The following are the violations disclosed:

(1) Failing to satisfy the requirements of the physician recruitment exception for an arrangement with one physician;

(2) Failing to satisfy the requirements of the fair market value (FMV) exception for arrangements with two physicians to provide medical director services;

(3) Failing to satisfy the requirements of the FMV exception for the provision of leadership stipends to thirteen physicians;

(4) Failing to satisfy the requirements of the personal services arrangement exception for an arrangement with a group practice to provide ophthalmology services.

(5) Failing to comply with the FMV exception for arrangements with two physicians to provide hospice services.

I repeat, this administration is all-in when it comes to combating healthcare abuses. As such, an annual compliance review is mandatory these days, both for healthcare facilities and physian medical practices.

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