Distance Learning Center

Educating and Connecting the Health Law Community.

The Stark Proposed Rule: Exploring the New FMV, Commercial Reasonableness and Volume or Value Guidance - On Demand Recording

Recorded On: 11/12/2019

Time: 90 minutes
Session Format: On Demand Recording
CLE Credit Available:  No

For on-demand webinar recordings, streaming access is available for 12-months from the date of the live webinar.  After 12-months, on-demand webinar recordings are available through the AHLA Health Law Archive.

On October 9, CMS issued a highly anticipated proposed rule aimed at modernizing and streamlining the Federal Stark Regulations.  The proposed rule contains extensive guidance on three critical regulatory requirements, fair market value, commercial reasonableness and the prohibition on “taking into account” the volume or value of a physician’s referrals.  Notably, CMS proposed modifications to the FMV definition, a new definition for commercial reasonableness and a bright-line standard for circumstances where compensation will be considered to “take into account” the volume or value of referrals.  Join leading industry experts, including the Chief Legal Officer for CMS, for an AHLA webinar that will focus on the proposed rule and this important Stark guidance.  This webinar will be complimentary for all AHLA members.

Level of Difficulty:  Intermediate

In most states, AHLA webinars meet the requirements for continuing legal education and attorneys may self-apply for CLE credit. AHLA’s live distance learning webinars are pre-approved for CLE credit in the following states: Alabama, Illinois, Nebraska, New Jersey, Pennsylvania, South Carolina, Texas, Virginia and West Virginia. Please refer to Distance Learning CLE reporting procedure for more information.

This webinar is sponsored by:

  • AHLA Member: $20
  • Non-AHLA Member: $30

This webinar is sponsored by:


Content Lead:

  • Hospitals and Health Systems Practice Group

This webinar is sponsored by:


​Joe N. Wolfe, JD (Moderator)


Hall Render Killian Heath & Lyman PC
Milwaukee, WI

Kelly Cleary

Deputy General Counsel & Chief Legal Officer

Centers for Medicare and Medicaid Services
Washington, DC

Kim Mobley

Managing Principal

Sullivan Cotter

Jen Johnson, CFA

Managing Director and Chief Commercial Officer

VMG Health
Dallas, TX

Charles B. Oppenheim


Hooper Lundy & Bookman PC
Los Angeles, CA

Jason Lee

Associate Principal

ECG Management Consultants

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