Can you imagine getting a memo from your hospital s compliance officer telling you that you can t provide more than $300 per year of CME to a physician that refers Medicare/Medicaid patients to your organization, and that you have to have the commercial supporter cut the check directly to faculty?

Believe it or not, that memo did go out to an organization recently, according to Denver attorney Jim Miles, of Miles & Peters, PC. It was in reaction to the Stark II regs I wrote about last week.

Stark II, which is aimed at ridding the system of Medicare and Medicaid abuse and fraud caused by hospitals or other organizations that handle Medicare/Medicaid patients wooing their best referrers with perks, firmly places CME in the perk realm, much to the dismay and annoyance of providers I ve been speaking with. Up to $300 per year can be exempted from the rule, or so it appears in the vaguely worded document after that, you risk noncompliance. Maybe.

Miles says that it s all a tempest in a teapot and, basically, don t worry about it. Here s a boiled down version of his reasoning (some of it will make it into the article for the next issue of Medical Meetings, but there s never space to say it all, so I ll blog it instead):

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