Authors: Fred Lara, CFA, ASA, CVA and Kevin Obletz, JD, CVA
Originally published by the American Association of Provider Compensation Professionals.
“The cornerstones of regulatory compliance, the concepts of commercial reasonableness and fair market value (“FMV”) are integral to demonstrating that a compensation arrangement complies with the federal Anti-Kickback Statute (“AKS”) and Stark Law. Specifically, unless covered by a “safe harbor,” the AKS is a criminal statute that prohibits the knowing and willful payment of . . .”