What is an example of a Stark Law exception for physician-owned entities?

• A. Outsourcing agreements
• B. In-office ancillary services (IOAS)
• C. Marketing agreements
• D. Unrelated party ownership

Answer: (B)

In-office ancillary services arrangements are an example of a Stark Law exception for physician-owned entities. This allows a physician practice to furnish and bill for certain ancillary services—like imaging, laboratory tests, or other designated health services—through an entity that is owned by the physicians in the practice, as long as specific safeguards are met. The services must be provided in the office or in a closely related setting, and the arrangement must be structured so that referrals are not driven by financial incentives. Key elements include ownership by physicians in the group, fair market value compensation, a prearranged plan, and the services being truly ancillary to the physician’s core practice. When these conditions are satisfied, the IOAS setup stands as a recognized exception to Stark’s self-referral rule.

Outsourcing agreements, marketing agreements, and ownership by unrelated parties do not automatically qualify as Stark Law exceptions for physician-owned entities in the same way, so they are not considered examples of the IOAS exception.