Which of the following is an example of a Stark Law exception used by physician-owned practices?

• A. Cross-referral marketing
• B. In-office ancillary services (IOAS)
• C. Non-compete clause
• D. Joint branding agreement

Answer: (B)

The concept being tested is how Stark Law permits certain in-house activities for physician-owned practices. The in-office ancillary services option is the example that fits best. This exception allows a physician who has an ownership or financial relationship with a practice to provide, perform, and bill for specific ancillary services within that same practice. When those services are truly in-office, properly designated as ancillary, and the arrangement meets the required conditions (such as the service being furnished in the same building and billed by the physician or practice), they can be legally billed to Medicare without triggering Stark self-referral concerns.

Cross-referral marketing isn’t an exception you can rely on to justify referral patterns; it concerns how referrals are promoted and can raise concerns about improper inducements. A non-compete clause addresses competition and employment considerations rather than Stark self-referral rules. Joint branding is a marketing arrangement and does not constitute an Stark exception for self-referrals.