Authors: Fred Lara, CFA, ASA, CVA and Kevin Obletz, JD, CVA
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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 . . .”