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    Comparison Chart of Stark Exceptions and Anti-Kickback Safe Harbors

    Please note that this resource does not yet reflect the changes to the Stark Law or Anti-Kickback Statute that were made final in November 2020. You can review these changes in our recent publication. If you have questions about how these final changes impact your organization, please contact Beth Kastner or Shannon DeBra.

    These charts have been updated to reflect the Stark law amendments and additions that are effective January 1, 2016, and are current as of November 2017. You also can review all the changes in this November 2015 publication

    Note that while we have made every effort to keep these charts accurate and timely, you should never rely on them entirely without also checking the actual regulatory language.

    Academic Medical Centers
    Ambulance Replenishing
    Ambulatory Surgery Centers
    Assistance to Compensate a Nonphysician Practitioner
    Certain Arrangements With Hospitals
    Charitable Donations by a Physician
    Community-Wide Health Information Systems
    Cooperative Hospital Service Organizations
    Compliance Training
    Electronic Health Records Items and Services
    Electronic Prescribing Items and Services
    Employment Relationships
    EPO and Other Dialysis-Related Drugs
    Eyeglasses and Contact Lens Following Cataract Surgery
    Fair Market Value Compensation
    Federally Qualified Health Centers
    Group Practice Arrangements With a Hospital
    Group Purchasing Organizations
    Implants in an ASC
    Increased Coverage, Reduced Cost-Sharing Amounts, or Reduced Premium Amounts Offered by Health Plans
    Indirect Compensation Arrangements
    In-Office Ancillary Services
    Intra-Family Rural Referrals
    Investment Interests
            Publicly-Traded Securities/Large Investment Interests
            Mutual Funds
            Investment Interests Held by Either Active or Passive Investors
            Investment Interests/Joint Ventures in Rural or Underserved Areas
            Investments in Group Practices
            Hospital Investment or Ownership
    Isolated Transactions
    Medical Staff Incidental Benefits
    Non-Monetary Compensation
    Obstetrical Malpractice Insurance Subsidies
    Payments by a Physician
    Personal Service Arrangements
    Physician Services
    Physician/Practitioner Recruitment
    Preventive Screening Tests, Immunizations, and Vaccines
    Price Reductions Offered by Contractors With Substantial Financial Risk to Managed Care Organizations
    Price Reductions Offered to Eligible Managed Care Organizations
    Price Reductions Offered to Health Plans
    Professional Courtesy
    Referral Agreements for Specialty Services
    Referral Services
    Rental of Office Space and Equipment
    Retention Payments in Underserved Areas
    Risk Sharing Agreements
    Sale of Practice
    Services Furnished by an Organization to Enrollees
    Timeshare Arrangements
    Waiver of Coinsurance and Deductibles