Phase 3, Stark II regulations

Phase 3 of the Stark regulations came out yesterday (thanks to colleague Reed Tinsely for the early heads up). I am still plowing through the 500 or so pages, but the Safe Harbor for physician compensation based on the various compensation surveys is gone. Seems as though CMS received numerous comments from affected parties that the Safe Harbor was not workable - and they agreed! Now we are back to traditional tests of fair market value compensation rather than the artificial Safe Harbor.

http://www.cms.hhs.gov/PhysicianSelfReferral/04a_regphase3.asp#TopOfPage