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    Comparison Chart of Anti-Kickback Safe Harbors and Stark Exceptions -- Compliance Training

    Compliance Training – Current as of November 2017

    Stark
    Stark exception to the referral prohibition related to a compensation arrangement for compliance training

    Anti-Kickback
    [No comparable safe harbor]

    The training is provided by an entity to a physician (or to the physician's immediate family member or office staff) who practices in the entity's local community or service area.

     
    The training is held in the local community or service area.  
    "Compliance training" means training regarding the basic elements of a compliance program (for example, establishing policies and procedures, training of staff, internal monitoring, or reporting); specific training regarding the requirements of Federal and State health care programs (for example, billing, coding, reasonable and necessary services, documentation, or unlawful referral arrangements); or training regarding other Federal, State, or local laws, regulations, or rules governing the conduct of the party for whom the training is provided. "Compliance training'' also includes programs that offer continuing medical education credit, provided that compliance training is the primary purpose of the program.