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J. William Bookwalter, III, M.D. which allows healthcare organizations to analyze physician compensation arrangements for fair market value and commercial reasonableness instantly. 411.362 Additional requirements concerning physician ownership and investment in hospitals. Sign Up for HSG's Physician Strategy News and Notifications on New Thought Leadership, Advanced Practice Provider (APP) Utilization, Fair Market Value and Commercial Reasonableness Opinions, Advanced Practice Provider (APP) Compensation, Download a PDF Version of the Article as Published in AHLAs 2021 Transactions Resource Guide to Share With Your Team, HSG Advisors Expands Consulting Services and Data Analytics Capabilities in Response to National Outpatient Utilization Trend, Creating a Win/Win System of Advanced Practice Provider Oversight, FPM Practice Pearls: HSG Advisors Shares How to Make APP Reviews Mutually Beneficial, Healthcare Provider Compensation in a Post-COVID, New MPFS Reality, Best Practices in Patient Attraction and Retention Strategies. A Primer on Fair Market Value - ByrdAdatto The following requirements must be bet under this exception: While this exception may be utilized in various situations, it is likely another exception, depending on the arrangement, would be more appropriate. Specifically, the aim of healthcare delivery is to provide high-quality care, high levels of access, and at the most cost-effective price. General market value is the compensation that would be included in a service agreement as the result of bona fide bargaining between well-informed parties who are not otherwise in a position to generate business for the other party. Modifying the definition of set in advance used in many Stark exceptions to allow modification of compensation during the term of an arrangement (including in the first year). 201 East Fifth Street Suite 1110 Cincinnati, OH 45202-4152 t: 513.870.6700 f: 513.870.6699. info@bricker.com. CMS Completes Sprint to Modernize the Stark Law-Part III First, it delineated that salary surveys or salary survey percentiles may not be appropriate to use in all circumstances. 2021 Stark Law and Anti-Kickback Statute: Fair Market Value Impact | HSG Specialties like critical care, hospital medicine, emergency medicine, and pulmonary medicine may have experienced increases in patient volume due to the pandemic. The following requirements must be [] Stark defines fair market value (FMV) as ______________________________ . For example, in the past some arrangements where physician compensation exceeded professional collections have received considerable scrutiny for commercial reasonableness.