Screen an arrangement for Stark and Anti-Kickback risk
This page lists three turns, the messages you send to the AI one after another in the same chat, and then a check of the answer. Keep it open next to your chat. Each turn shows the next thing to paste, with the values you entered already filled in. Nothing is sent from this page, and your conversation stays in the AI tool you are using.
Parties, services, term, payer mix, what designated health services the entity furnishes, and every other relationship with the same physician. Paste the agreement if you have it.
The actual arithmetic (base, per-hour, per-unit, bonus triggers, stipends), not the label the parties use.
The state whose self-referral, fee-splitting, corporate-practice, and licensure rules apply.
Decides whether the output is a structuring path or a disclosure analysis.
The entity, the physician, or a buyer; the answer changes what you would advise.
Watch for these throughout
Stark exceptions and Anti-Kickback safe harbors are amended regularly and their elements are unforgiving. Read the current regulatory text for every element before relying on any conclusion here. Do not accept an element list the model produced from memory.
Stark is strict liability. A well-intentioned arrangement that misses one element of one exception is prohibited, and the payment consequences run from the first tainted referral.
Missing an Anti-Kickback safe harbor does not make an arrangement unlawful, and fitting one does nothing for Stark. Any memo that blends the two conclusions will mislead the client precisely where it matters.
Every financial relationship between the physician and the entity is assessed together. Screening one agreement in isolation is the most common way these reviews go wrong.
If payments have already been made, this is a disclosure and repayment question with its own timelines, and the analysis should be run under privilege with the client's knowledge before anyone writes a conclusion down.