CMS Has Spoken: FMV and Commercial Reasonableness Under the New Stark Regulations

Understand the new definitions of fair market value (“FMV”), general market value (“GMV”), and commercial reasonableness (“CR”)

Examine the updated criteria for determining FMV, GMV, and CR

Apply the new framework for using and not using survey data or FMV and GMV

Evaluate the impact of practice losses for FMV and CR purposes