National Intelligence Report

The Centers for Medicare and Medicaid Services has put the finishing touches on new requirements that physicians who own physician organizations will be treated as "standing in the shoes" of those entities for purposes of complying with the Stark self-referral law. Under the ‘stand in the shoes’ analysis, physicians referring Medicare or Medicaid patients to an entity for clinical lab and other designated health services are considered to have the same compensation arrangements with the entity as the physician organization in which they have ownership interest.