Stark Update

On Aug. 19, 2008, the Centers for Medicare and Medicaid Services (CMS) published the final 2009 Inpatient Prospective Payment System (PPS) Rule (Final Rule) in the Federal Register. CMS included several significant Stark rule changes in the Final Rule, including clarification to the "stand in the shoes" provisions first introduced in the Sept. 5, 2007 (Phase III) final rule, changes that will significantly limit "under arrangement" transactions and a prohibition on the use of per-click and percentage-based compensation arrangements for space and equipment leases. Several of the changes were effective Oct. 1, 2008; others will not be effective until Oct. 1, 2009.

Click on the PDF link above to view the full memorandum.