Bass, Berry & Sims attorney Danielle Sloane provided insight for an article in Modern Healthcare outlining recent settlements involving Stark Law violations related to physician compensation. The article specifically looks at three cases (United States of America v. North Broward Hospital District, et al. and United States ex rel. Drakeford v. Tuomey Healthcare System, Inc. and Payne et al. v. Adventist Health System-Sunbelt Inc. et al. / Sherry Dorsey v. Adventist Health System Sunbelt Healthcare Corp. et al) in which whistleblowers alerted the U.S. Justice Department about the alleged violations.

Danielle provided several helpful tips on complying with the Stark Law, such as 

  • “Periodically re-evaluate whether a physician’s pay reflects fair market value and is commercially reasonable without considering referrals.”
  • “Keep gifts, meals and other nonmonetary compensation to referring physicians below $392 in 2016, and document them.”

Danielle’s remaining tips can be found in the full article, “Whistle-blower Worries: Hospitals Likely to See More False Claims Suits Tied to Doctor Compensation,” that was published by Modern Healthcare on November 21, 2015 and is available online.