February 18, 2020

February 18, 2020

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February 17, 2020

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CMS Updates Non-Monetary Compensation and Medical Staff Incidental Benefit Limits under Stark Law

The Centers for Medicare and Medicaid Services recently posted its 2015 limits on non-monetary compensation and medical staff incidental benefits. The Stark Law provides two exceptions for relatively minor remuneration provided to a referring physician.

Under the non-monetary compensation exception, a hospital or other entity may provide up to the non-monetary compensation limit for items or services (but not cash or cash equivalents) provided to a physician. For calendar year 2015, the aggregate limit is $392, which is a slight increase from $385 in 2014.

The medical staff incidental benefits exception permits a hospital and other entities with medical staffs to provide “low value” items and services to its medical staff (or a particular specialty of the medical staff). For calendar year 2015, the maximum value of incidental benefits is $33, which is one dollar higher than 2014.

Both the non-monetary compensation and medical staff incidental benefits exceptions have additional requirements.

The 2015 limits and previous limits can be viewed here.

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von Briesen & Roper’s Health Law Section provides comprehensive legal services to the health care industry nationwide as both general counsel and special project counsel. Our clients include integrated delivery systems, academic medical centers, community hospitals, Catholic-sponsored hospitals, rural and critical access hospitals, imaging centers, physicians and multi-specialty clinics, specialty hospitals, ancillary suppliers, home health agencies, nursing homes, hospices, assisted living facilities, mental health and AODA facilities, DME suppliers, laboratories,...