The author penned this article before joining Nelson Mullins Riley & Scarborough LLP

Do you represent a hospital, physician, or physician-owned entity involved in an arrangement pursuant to which a physician-owned entity provides services to a hospital, which then bills for part or all of the service?

This article is a follow-up to my February 2009 AHLA Executive Summary entitled, “Will Your Clients’ ‘Under Arrangements’ Relationships Remain Compliant with the Stark Law?” Because a recent case that challenged a change in the federal physician self-referral rules (Stark Law)1 did not survive a jurisdictional challenge, many of these service arrangements — also known as “under arrangements” relationships—between hospitals and physician-owned, third-party service providers will fall out of compliance with the Stark Law on October 1, 2009. There are only a few months left until October 1, 2009, so now is the time to review these service arrangements.

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