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Healthcare Leases & Stark Law Compliance

October 1, 2022

Thought Leadership

Stark Law and Anti-Kickback compliance requires ongoing effort and monitoring. Similar to other regulations and standards, like those for lease accounting, thinking beyond the initial adoption prevents repeated projects and mitigates financial exposure and risk. Under the Stark Law, healthcare organizations can be found guilty whether the problem was intentional or not. Penalties and fines can be substantial – well into the millions of dollars.

One area of compliance focus should be on healthcare lease portfolios. Healthcare real estate is complex. Owned property, leased property, sale-leaseback transactions, leases between hospitals and physicians, timeshare arrangements, and other situations add intricate layers of contracts that need to be managed. Add medical equipment leases to the picture and the minimum effort needed to effectively administer the entire leased asset portfolio increases exponentially.

Where to begin…

At the very base of all portfolio level compliance efforts are the documents and contracts that describe the relationships between the parties. These documents are critical for understanding where there may be compliance risk and what each party’s legal rights and obligations are. The documents are also a first line of defense when guarding against claims, should any arise.

Scribcor has created a checklist to help you evaluate the state of your documentation. You can access this checklist here.

Contracts and documentation are at the root of Stark Law and Anti-Kickback compliance for healthcare lease portfolios. Scribcor supports compliance with these and other related regulations, applying client-centric processes that ease uncertainty so you can Know. Right. Now. If you would like to learn more, visit

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