Stark Law & AKS Compliance Plan

Produces a defensible compliance plan covering physician self-referral prohibitions (Stark Law, 42 U.S.C. § 1395nn) and anti-kickback requirements (AKS, 42 U.S.C. § 1320a-7b(b)), tailored to the organization's arrangements and risk profile.

Prerequisites

1. Organizational documents — corporate structure, service lines, covered entities
2. Physician arrangement inventory — employment agreements, PSAs, medical directorships, leases, JV interests, recruitment packages
3. Referral data — volume by physician, service type, payer
4. Compliance history — audit findings, OIG/CMS correspondence, prior self-disclosures
5. Compensation data — physician pay, FMV assessments, survey benchmarks

Quick Start