WEBINAR | The Stark Proposed Rule

Join us on November 12 for a webinar presented by the American Health Lawyers Association (AHLA).

SullivanCotter's Kim Mobley, Managing Principal, will serve as a panelist during this session, which is entitled The Stark Proposed Rule: Exploring the New FMV, Commercial Reasonableness, and Volume or Value Guidance.

On October 9, CMS issued a highly anticipated proposed rule aimed at modernizing and streamlining the Federal Stark Regulations. The proposed rule contains extensive guidance on three critical regulatory requirements, fair market value, commercial reasonableness, and the prohibition on “taking into account” the volume or value of a physician’s referrals.

Notably, CMS proposed modifications to the FMV definition, a new definition for commercial reasonableness, and a bright-line standard for circumstances where compensation will be considered to “take into account” the volume or value of referrals. Join leading industry experts, including the Chief Legal Officer for CMS, for an AHLA webinar that will focus on the proposed rule and this important Stark guidance. This webinar will be complimentary for all AHLA members.