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Last year, CMS finalized a number of significant changes to the Stark Law. Now that these changes have gone into effect, health care organizations should be monitoring and auditing their existing arrangements to ensure they are compliant with Stark’s technical requirements and key tenets of defensibility (e.g., fair market value, commercial reasonableness, and not taking into account designated health service referrals) in case their physician arrangements are ever challenged.


  • In this session Mr. Wolfe will provide an overview of the Stark Law, including its 2016 changes.
  • He will also discuss best practices for auditing physician compensation arrangements on behalf of health systems, hospitals, medical groups and physician practices.
  • The webinar will focus on regulatory requirements, key provisions, valuation considerations and potential pitfalls that should be avoided.


Healthcare reform has invigorated the government’s focus on healthcare fraud, including enforcement of the Stark Law. Improper design and implementation of physician arrangements can result in penalties, denial of payments, and exclusion from federal health care programs. Thus, ensuring Stark Law compliance will be critical for medical groups, hospitals and health systems looking to manage areas of enterprise risk.

Health care organizations should periodically audit their existing arrangements to ensure they are compliant with Stark’s technical requirements and key tenets of defensibility (e.g., fair market value, commercial reasonableness, and not taking into account designated health service referrals, etc.) in case their physician compensation arrangements are ever challenged.

This webinar will offer best practices for implementing and auditing physician compensation arrangements to minimize liability exposure and penalties, including conducting compliance audits, instituting policies, and establishing ongoing monitoring and reviews.


  • Provide a general Stark Law Overview
  • Examine critical regulatory requirements related to physician compensation arrangements
  • Review processes for documenting fair market value and commercial reasonableness
  • Discuss best practices for auditing physician compensation arrangements and potential pitfalls
  • Discuss how to resolve issues that may arise during the audit process


  • In-House Counsel
  • Health Care Compliance Officers
  • Health Care Human Resources
  • Health Care CFOs
  • Health Care executives


Joseph Wolfe is a partner with Hall, Render, Killian, Heath & Lyman, P.C., the largest health care focused law firm in the country, now with offices nationwide. Hall Render's attorneys provide advice and counsel to many of the nation's largest health systems, hospitals and medical groups on a variety of health care issues. Mr. Wolfe regularly counsels clients on a national basis regarding compliance-focused physician compensation strategies. He is a frequent speaker on issues related to the physician self-referral statute (Stark Law), hospital-physician transactions, physician compensation and health care fair market value issues. Before attending law school at the University of Wisconsin, he served as a combat engineer in the United States Army.

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