The October 1st Stark Law Changes: Implications for Diagnostic Imaging Arrangements

By Adrienne Dresevic, Esq. and Carey F. Kalmowitz, Esq.

August 2009 — Last year, on August 19, 2008, the Centers for Medicare and Medicaid Services (“CMS”) published final Stark rules in its 2009 Final Hospital Inpatient Prospective Payment Systems Rule (the “Final Rule”). The Final Rule contains 3 significant modifications to the Stark regulations which become effective this year on October 1, 2009. This article addresses these modifications and their implications for common diagnostic imaging arrangements.