July 13, 2015

With surprisingly little fanfare, the CY 2016 Physician Fee Schedule (the “Proposed Rule”) released on July 8, 2015 proposes to add and amend several exceptions to the Physician Self-Referral Statute, commonly known as the Stark Law.

The Proposed Rule has the potential to limit instances of “technical” noncompliance with the Stark Law by extending the holdover “grace period” permitted under exceptions for leases and services arrangements. It also calls into question whether timeshare arrangements commonly used in the health care industry require restructuring to meet a proposed stricter “timeshare arrangements” exception.

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