Week 9 Student-Led Live Session Assignment

As you have read in the materials, the Federal Anti-Kickback Statute and Physician

Self-Referral (Stark) Law and their exceptions are voluminous and have very

significant implications for healthcare organizations. Given their complexity, they are

not readily accessible on a day-to-day, on-the-spot basis. You need to have at your

fingertips the key elements of these legal frameworks (see below) so you can readily

identify potential issues and take appropriate and timely action.

Your group is to assume that you are members of the compliance department in a

large hospital system. Working in your groups, develop a checklist for either the

Federal Anti-Kickback Statute or the Stark Law (as assigned below) that you could

use to review certain arrangements for potential violations. In your checklists, focus

on the elements referenced below. Your checklists should be brief distillations of

these elements but contain enough information to be useful on a daily basis.

Physician Self-Referral (Stark) Law

• Key elements of the prohibition (including definitions, where appropriate)
• Any other key elements (e.g., time frames, penalties)
• List of most relevant exceptions
• A brief description and/or key elements of each exception listed (including definitions, where appropriate)

make Sure you Format as a memo