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Annual nonmonetary compensation reviews

Betsy Wade ( is the Chief Compliance and Ethics Officer at Signature Healthcare in Louisville, KY.

As midyear approaches, now is a good time for compliance departments to review their annual nonmonetary compensation totals to ensure the Centers for Medicare & Medicaid Services (CMS) cap has not been reached or exceeded.

According to the federal Stark Law, CMS annually sets the nonmonetary compensation (gifts) and medical staff incidental benefits limits for physicians and their immediate family members.[1] The limit is adjusted each calendar year in December to the nearest whole dollar by the increase in the Consumer Price Index-Urban All Item (CPI-U) for the 12-month period ending the preceding September 30.

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