Centers for Medicare & Medicaid Services (CMS) clarified the definition of indirect compensation arrangement and its guidance regarding personal productivity. Together, CMS’ Modernizing and Clarifying the Physician Self-Referral Regulations, effective January 19, 2021, and the 2022 MPFS, effective January 1, 2022, shine a new light on physician compensation models involving work relative value unit (wRVU) productivity. The revisions within this guidance require a more careful look at whether physician compensation is fair market value, is commercially reasonable, and meets the volume or value/other business generated requirements under the Stark Law.

PYA Principal Angie Caldwell will join Foley & Lardner Partner Jana Kolarik for a virtual discussion and Q&A as part of the Let’s Talk Compliance series.

Attendees are encouraged to submit questions before the discussion and participate in dialogue on physician compensation and concerns organizations may have with the new regulatory changes.