The federal physician self-referral ban or "Stark Law" has been a major part of the legal landscape for almost 25 years. It is known for its breadth of prohibitions, strict liability formulation, and draconian remedies presenting major challenges for health care transactions involving physicians. Stark compliance has always been a moving target and the developments of this past summer illustrate the continued evolution of the self-referral prohibition.
Partner Bob Homchick and Associate Kyle Gotchy of DWT gave this presentation September 22, 2015. Topics included:
- Examination of the proposed regulations
- Summaries of the recent developments in the Self-Referral Disclosure Protocol (SRDP)
- Examination of the recent Tuomey ruling and implications for the statute
- Discussion of the CMS Comprehensive Care for Joint Replacement Model (CCJR) and Stark Waivers articulated in the proposed regulations