In this Article, I will focus on common compensation models when the referring physician is a W-2 employee. Under the employment exception of the Stark Law, the required elements are as follows: i) services must be specifically identified; ii) compensation must be consistent with fair market value; iii) compensation cannot be determined in a manner that takes into account the volume or value of referrals; iv) compensation terms, including amounts, must be commercially reasonable; and v) if a “productivity bonus” is paid, the productivity bonus must be based on the employed physician’s personally performed services.
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