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This one-day seminar is designed for attorneys, administrators, compliance officers, business and office managers, health care providers, presidents, vice presidents, nurses and physicians.
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Select Topics In The Stark II Phase II Regulations  

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This one-day seminar is designed for attorneys, administrators, compliance officers, business and office managers, health care providers, presidents, vice presidents, nurses and physicians.

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Seminar Summary:

The purpose of this seminar is to offer attendees a practical understanding of the impact of the Phase II regulations on their businesses and existing financial arrangements. (see full course description)

 
 

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Training Course Syllabus:


On March 26, 2004, the Centers for Medicare and Medicaid Services issued Phase II of its two-part regulations implementing the federal physician self-referral law or 'Stark Law.' The Phase II regulations, effective July 26, 2004, cover those parts of the Stark Law not covered by Phase I - ownership and investment exceptions, compensation arrangement exceptions and the Stark Law's reporting provisions. Phase II creates new flexibility for some arrangements and greater obstacles for others.

The purpose of this seminar is to offer attendees a practical understanding of the impact of the Phase II regulations on their businesses and existing financial arrangements.

Seminar highlights:

  • Percentage compensation arrangements
  • Physician recruitment and retention
  • Fair market value exception
  • Key definition changes

Learning objectives:

  • The attendee will be able to discuss productivity bonuses and profit-sharing.
  • The attendee will be able to identify when to get a fair market value opinion.
  • The attendee will be able to review new exceptions.

9:00 a.m. - 9:35 a.m.

I. 'Referral' Definition

A. Personally Performed DHS

B. Specialist Exception

9:35 a.m. - 10:10 a.m.

II. Percentage Compensation Arrangements

A. 'Set In Advance' Definition

10:10 a.m. - 10:25 a.m.

Break

10:25 a.m. - 11:00 a.m.

III. Group Practices

A. Single Legal Entity

B. 'Substantially All' Test

C. Productivity Bonuses And Profit-Sharing

D. In-Office Ancillary Services Exception

E. Same-Building Requirement

11:00 a.m. - 11:35 a.m.

IV. Indirect Compensation Arrangements

A. Definition

B. Exception

C. Special Compensation Rules

11:35 a.m. - 12:15 p.m.

V. Physician Recruitment/Retention

A. Relocation Requirement

B. Residents/New Physicians

C. Physician Group Recruitment And Incremental Overhead Costs

D. Physician Retention Payments

12:15 p.m. - 1:15 p.m.

Lunch (On Your Own)

1:15 p.m. - 1:50 p.m.

VI. Employment Relationships

A. Productivity Bonuses

B. Supervision Payments

1:50 p.m. - 2:25 p.m.

VII. Fair Market Value Exception

A. 'Safe Harbor' Methodologies

2:25 p.m. - 2:40 p.m.

Break

2:40 p.m. - 3:15 p.m.

VIII. Isolated Transactions Exception

A. Installment Payments

B. Post-Closing Adjustments

3:15 p.m. - 3:50 p.m.

IX. Academic Medical Centers

A. FMV Physician Compensation

B. Faculty Practice Plans

3:50 p.m. - 4:30 p.m.

X. New Exceptions

A. Charitable Donations

B. Professional Courtesy

C. Community Health Information Systems

D. Temporary Lapses In Compliance

Seminar Summary:

The purpose of this seminar is to offer attendees a practical understanding of the impact of the Phase II regulations on their businesses and existing financial arrangements. (see full course description)

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