Health systems’ real estate arrangements with referral sources face numerous compliance pitfalls, any one of which can trigger a violation under the Stark Law. The compliance pitfalls associated with real estate arrangements can be generally subdivided into two categories: (1) transactional and (2) operational.
Transactional compliance pitfalls stem from the real estate arrangement itself and the specific structure of the transaction.
Operational compliance pitfalls stem from the subsequent administration, or lack thereof, of the real estate arrangements
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