The Key to Successfully Working with Physician Referral Sources Is Understanding the New STARK Guidance

Physician relationships are key to succeeding in today’s competitive environment and pharmacies that work on building those relationships will flourish.  Unfortunately, because the government has chosen to regulate the healthcare industry this means that what is allowed in other industries may not be allowed in healthcare. The STARK Law is one of those regulations that changes the rules. The STARK law was put in place to prohibit overutilization by physicians by creating limits to a physician’s ability to refer designated health services such as outpatient prescription drugs to an entity in which the physician has a financial relationship. As a result, anytime a pharmacy has a financial relationship with a physician, the pharmacy must analyze its activities for compliance with STARK. STARK was first enacted in 1989 and over time the reimbursement models have evolved from almost exclusively fee for service to a value-based model. CMS has recently issued new guidance and exceptions to STARK that address value-based compensation models.

This program will discuss recently published STARK guidance that applies to relationships between pharmacies and physicians. Understanding this new guidance will be important to working with physicians as suppliers develop these key relationships.