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