The New Stark II Phase III Rules: Strategies to Interpret and Comply with Updated Regulations

Partner Lawrence Vernaglia is speaking at the Center for Business Intelligence’s (CBI) forum on The New Stark II Phase III Rules: Strategies to Interpret and Comply with Updated Regulations, June 23, 2008 in Alexandria, Virginia.

Mr. Vernaglia is speaking from 4:00 p.m. – 4:45 p.m. with Lisa Ohrin, Deputy Director of the Division of Technical Payment Policy, Centers for Medicare & Medicaid Services. Their session is titled “Navigating the Road Ahead — Further Evolution in the Stark Laws. While Phase III initially appeared in some respects to be more flexible than its predecessors, the changes to the indirect compensation relationship analysis introduced additional complexities and has far-reaching practical implications as providers evaluate compliance of their existing relationships. In the same sense, remaining under consideration are other proposals that may ultimately amend the Stark regulations in a more narrow and restrictive fashion, including, for example, limitations on per-click equipment and space leases, narrowing of the in-office ancillary services exception and modifications to the whole hospital exception. This session features the lead attorney who drafted Stark Phase III from the Centers for Medicare and Medicaid Services and addresses the key current questions of Stark implementation, as well as what’s next on the horizon, presenting healthcare providers the opportunity to better prepare themselves for further change.