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Ready, set, go—for 2022 Stark group practice compliance!

Lester J. Perling ( is a Partner in the Fort Lauderdale office of Nelson Mullins Riley & Scarborough. He is board certified as a specialist in health law by the Florida Bar. Hannah L. Cross ( is a Partner in the Washington, DC, office of Nelson Mullins Riley & Scarborough.

It is time for group practices to finalize revisions, if any, to compensation for 2022. Almost one year after the Centers for Medicare & Medicaid Services (CMS) published its final rule amending the Physician Self-Referral Law (Stark Law) regulations,[1] group practices will soon be expected to comply with the revised version of the special rules for profit shares and productivity bonuses. Despite the extra time CMS afforded group practices to consider and revise their compensation models, complexities of the ongoing pandemic in conjunction with difficulties of everyday life may have left some group practices unprepared for these changes. This article highlights the new group practice regulation, effective January 1, 2022, and is a tool for group practices to use when reviewing and revising their compensation models.

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