Authors: Fred Lara, CFA, ASA, CVA and Kevin Obletz, JD, CVA
![](https://healthcareappraisers.com/wp-content/uploads/2020/01/FMVantagePtLogo_Tag_CoolGray9.png)
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 . . .”