The government relies on a complex arsenal of rules and regulations to combat fraud and abuse in the Medicare and Medicaid systems. One component of that arsenal is the Federal physician self-referral prohibition – commonly known as “The Stark Law” or “Stark”. Introduced in 1989, the Stark Law was intended to simplify regulatory compliance and enforcement by establishing bright line rules prohibiting specific financial arrangements that the government believed posed a significant risk of fraud and abuse in the Medicare and Medicaid systems, because those arrangements incentivized the order or purchase of unnecessary healthcare items or services for which the government ultimately would be financially responsible. Consequently, Stark is a strict liability statute – meaning any violation of the prohibition, even if unintentional or an unintended consequence of some legal activity, exposes the parties to significant administrative, civil and criminal penalties. Over the years, the Stark Law has been revised and expanded in an effort to keep up with the many creative ways the market sought to generate revenue without running afoul of law’s restrictions. The result of all of this activity is a convoluted labyrinth of rules, definitions and exceptions that are difficult to understand, and even more difficult to apply to everyday operations. In this presentation, Ms. Jacobs will introduce participants to the Stark Law and provide a framework for understanding how the law might apply to some common healthcare industry arrangements.