Establishing a Flexible Template for a Stark Analysis

22 June 2010 Washington, D.C. Past Event

Location

Washington, D.C.

Contact Information

Susan Stewart
sstewart@foley.com

Agenda

June 22-23, 2010
Foley Partner Larry Vernaglia will speak on “Establishing a Flexible Template for a Stark Analysis” at ACI’s Health Care Enforcement Summit on June 22-23, 2010 in Washington, DC.

This panel presentation will focus on the following topics:

  • Identifying when and under what circumstances Stark applies
  • Organization of facts critical to formulating the analysis
  • Navigating and tying agreements to substantive Stark exceptions
  • What are the common exceptions?
  • Recent revisions to Stark
  • defining an “entity”
  • “per click”
  • Calculating Fair Market Value
  • Sources
  • Tabulating and assigning value within the context of the situation and for the locality
  • How do you determine whether an agreement completely fits an exception?
  • The danger of being too conservative
  • Ensuring a commercially reasonable business rationale
  • Meeting the technical requirements of Stark provisions

Related Services

Establishing a Flexible Template for a Stark Analysis

Location

Washington, D.C.

Contact Information

Susan Stewart
sstewart@foley.com

Agenda

June 22-23, 2010