CMS and HHS made adjustments to the Stark Law and Anti-Kickback Statute Jan. 19, affecting calculations of fair market value for physician pay.
Jen Johnson, managing director, chief commercial officer and head of compensation arrangements, and Anthony Domanico, director of compensation design and consulting at VMG Health, outlined how organizations should think about physician pay in a Feb. 24 article.
1. CMS unveiled three definitions for fair market value in the new rule, focused on general services, equipment rental and office space.
2. The final rule defines general market value of compensation as “compensation that would be paid at the time the parties enter into the service agreement as a result of bona fide bargaining between well-informed parties that are not otherwise in a position to generate business for each other.”