Eye of the storm--the government's focus on hospital-physician arrangements

Stand in the Shoes In the Phase III regulations, CMS issued a new rule deeming a physician to "stand in the shoes" of his/her physician organization for purposes of applying the rules that describe direct and indirect compensation arrangements.13 If a physician stands in the shoes of his/her physician organization, the physician generally will have to satisfy a stringent direct compensation arrangement exception without having the option of utilizing the "indirect compensation exception." [...] the effect of the Phase III regulations was to convert a significant amount of what used to be indirect relationships between hospitals and physicians into direct financial relationships that did not qualify for any Stark Law exception.\n Initial steps may include: * Allocating enough personnel and other resources (such as a contract management system) to conduct the assessment, * Determining the assessment period, * Identifying the scope of the assessment, including the number of arrangements to analyze in detail (that is, deciding between sampling vs. total analysis).