Thirty-five years is long enough. Here is what Stark modernization actually looks like.
This week built toward a simple argument. The Stark Law was written for a healthcare system that no longer exists, produced consequences its own author called harmful, and has never been modernized to reflect the accountability tools that now govern the delivery of care. The data confirm the direction we are headed is wrong. Stark enforcement surged in 2024 with 979 whistleblower lawsuits and $2.92 billion in False Claims Act settlements with increased prosecution for Stark violations alone. The law is accelerating in the wrong direction at the exact moment it needs modernization.
The Medical Group Management Association has labeled Stark a major regulatory burden. Bipartisan lawmakers floated reforms including a 2024 House bill to expand in-office exemptions. The momentum exists but what has been missing is a coherent framework. Well…. Here’s a good start:
Prior Authorization Safe Harbor. Any designated health service subject to prospective prior authorization or qualified utilization review should qualify for a Stark exception. The external check Stark was designed to provide already exists everywhere. The prohibition is redundant and anticompetitive.
Physician-Owned Hospital Conditional Exception. POHs that participate in WISeR or subject their procedures to Medicare Advantage utilization review should have a conditional pathway back. Accountability in exchange for ownership rights is a trade worth making.
Independent Practice Cooperative Exception. Independent physicians under separate TINs cannot jointly own imaging or rehabilitation equipment and self-refer even though a large single-entity group can. The result is that independent orthopedic and spine practices cannot collectively own an MRI, forcing patients into hospital outpatient departments where the same study costs two to four times as much. A cooperative exception with prior authorization and ownership disclosure requirements would bring independent physician-owned imaging back into the market and give patients a lower-cost alternative that current law has systematically eliminated.
Anti-Steering Provision. Health systems should be prohibited from contractually requiring employed physicians to refer exclusively within the system when an independent option would better serve the patient. Patients should know when their physician’s compensation depends on keeping referrals in-house.
IOAS Defense. The in-office ancillary services exception is under constant lobbying pressure from various special interest groups. Protecting and expanding it for small independent practices is a Stark priority, not an afterthought.
As one Baltimore orthopedic surgeon told Becker’s this week: “We’ve created a system where for-profit entities can have healthcare ownership. But the people who took an oath to serve the patient — who’ve shown a commitment to caring — can’t.”
That is a healthcare system designed around institutional advantage instead of patients. The framework above doesn’t eliminate oversight. The framework rebuilds oversight around the healthcare system that actually exists today with accountability mechanisms that work and ownership rights applied equally regardless of whether you have a hospital’s legal department or your own.
Independent physicians built this system but have been progressively excluded and marginalized over the last few decades. They deserve to participate in it on equal terms.
Interested to hear details of this case.
You’re on your own for healthcare?
The combined state and local spending on healthcare is $2.8 trillion dollars. That’s more than the ENTIRE budget of all but two countries on earth (US & china).
Medicare and medicaid are two of the most generous benefits in the world.
Watson walked free after killing an 84-year-old man in San Francisco in 2021, leaving the community devastated.
https://americancommunitymedia.org/news-exchange/justice-denied-for-late-grandpa-vicha/
NEW: San Francisco judge Linda Colfax has released a man who fatally assaulted an 84-year-old because the prison sentence would have a "poor impact" on him.
25-year-old Antoine Watson was granted probation just two months after he was convicted of involuntary manslaughter and assault.
Watson violently assaulted Vicha Ratanapakdee in 2021, which resulted in his death just two days later.
He was acquitted of first-and second-degree murder charges and instead convicted of involuntary manslaughter.
Colfax says Watson being in prison would have a "poor impact" on him and didn't think he should be there because he "expressed remorse," according to the SF Chronicle.
Colfax is accused of hiding details from the jury in an apparent effort to help Watson escape prison time.
Infuriating and evil.
🚨 JUST IN: Stephen Miller lays it out PERFECTLY
Imagine a "native Minnesotan who works as a lineman...worried about his ability to support for and provide his family."
"And then imagine that he has a neighbor who's a SOMALI REFUGEE who arrived two years ago and has a Mercedes and NO financial stress and no worries at all in the entire world and never seems to ever go to work at all because he just went to an office in the state, lied on a piece of paper, and got unlimited free money forever for life!"
"THAT is the system that is being run and that is the corruption that this task force under the leadership of the Vice President is going to demolish." @StephenM
The reason many of our leaders hate people like Nayib Bukele in El Salvador is because he has quickly proven that crime and societal decline are not inevitable or beyond control…
It’s a deliberate choice allowed by weak leaders, terrible policies and suicidal empathy.
The number of J1 doctors training in US hospitals has
increased 54% over the past decade.
Intealth/ECFMG, the sole sponsor of foreign medical students, is a private non-profit with no government oversight.
You bet! They are very much on my radar. I have a long list of issues with them, but my top three are
1) Charity care/“community benefit” for tax exempt status is a boondoggle.
2) Buying up physician practices, employing doctors, creating care monopolies, charging facility fees for office visits.
3) Abusing the heck out of the 340B program.
I have model policy on all three. The Charity Care one is up for consideration at our next NCOIL meeting…
https://ncoil.org/wp-content/uploads/2026/03/NCOIL-Charity-Care-Model-Draft-March-2026.pdf
When a patient is in the hospital, doctors used to use paper notes to communicate with one another.
In the EHR era, the note stopped being a clinical communication tool and became a billing and compliance artifact. The results have been a disaster.
One JAMA study found notes got 60.1% longer from 2009 to 2018, while redundancy rose 22%. ONC has explicitly acknowledged that clinicians use templates to stuff notes with unnecessary information into the chart to meet billing requirements, creating note bloat.
The clinical note was no longer a method of communication. It was a billing document.
So hospitals layered secure chat on top just to communicate the actual plan of care. And even that workaround is not working.
A 2024 JAMA study found more secure messaging was associated with more time on the phone, not less. Doctors needed to call to clarify the now constant message stream.
Another study found higher messaging volume was associated with higher odds of errors. More messages means a higher cognitive load with most of the information being low-importance. This increased cognitive load leads to more errors.
We took what should have been efficiency improving technology, a computerized chart, and so over-regulated it and misaligned incentives that it has led to harmful downstream effects.
Now, please don't do this with AI...
I will be keeping a very close eye on this committee. 👀 I hope you’ll audit the “non-profit” hospitals.
Start by auditing “non-profit” hospitals in Texas - the ones that advertise night and day on TV and radio, sponsor professional sports teams and pay their CEO over $6MM a year.
Let’s do something about the “non-profit” hospitals abusing their tax-free status at the expense of everyone else. If a hospital can afford to sponsor professional sports teams, advertise day and night on TV and radio, and pay their executives multimillion salaries, then they can pay taxes!!!
Medicaid payments don't come close to matching commercial insurance payments.
So an American graduate with $400,000 of debt should practice in rural Kentucky for what reason?
Medicaid expansion post Obamacare made access to elective medical care worse, not better.
Dr. Digiorgio @DrDiGiorgio explains the Stark Law- why you should care about it !
Live @DRsLoungePod -- @DrDiGiorgio on his congressional testimony on solutions for our health care morass.
Welcome to our live show! https://x.com/i/broadcasts/1nxeLyZYwnvJX
I wanted to practice rural medicine🤷♂️
And there are actually local community members in America that have roots that are much more likely to stay — we have just made it too difficult for them to traverse the medical education system.
Not theoretical - look at the story of osteopathic medical school of Philadelphia and the 1 year training program. A generation of mostly Local South Philly Italian boys and girls from the community became doctors and still serve the community.
Just like American medical graduates , IMGs seek to escape rural poor areas as quickly as possible.. which is why despite allowing IMG galore into the US and allowing non physicians to practice without a medical license the rural poor access problem continues.
If serving the poor was the main motivation for IMGs, why wouldn’t they serve the rural poor in their own countries that are significantly worse off?
Tim Tebow hosted a red carpet event called 'Night to Shine' to celebrate and uplift individuals with special needs ❤️
Too hard to do, also the media is garbage and will run a non stop op against anyone that tried to do anything actually useful.
Get rid of Medicare Advantage, MACRA, MIPS, CMMI, etc., and stop privileging huge hospital systems over independent physicians.
THIS is America and exactly why we shouldn’t be casually handing out opportunities to foreigners.
https://www.nytimes.com/2026/03/26/us/politics/trump-medical-schools-civil-rights.html?smid=nytcore-ios-share&referringSource=articleShare via @NYTimes
The scandal of elevating diversity over merit in medical education must end. There is no evidentiary basis for this practice, no legal basis for this practice, and no ethical basis for it. Just “good enough” is unacceptable.
The “heart of scientific authority” where objective measures are disregarded in favor of ideology and social activism in their discriminatory admissions policies?
“Measles has re-emerged in the United States because of low vaccination rates and reintroduction of the virus from endemic countries.”
Interesting public health authorities who have no problem preventing you from going to your local place of worship during an epidemic view travel to the US from endemic countries as something that can’t ever be touched.
"God gave me strength, I couldn't let them folks die"
16 yr old Corion Evans was hanging out with his friends when he saw a car PLUNGE into the Pascagoula River in Mississippi.
3 teenage girls began screaming for help as the car quickly sank.
Evans immediately sprang into action, diving in to rescue the girls.
When asked where his bravery came from, he replied "God gave me strength, I couldn't let them folks die."
Police Officer Gary Mercer assisted Evans with the rescue, but he began to drown as well when one of the panicking victims tried to pull him under.
Despite being out of breath with exhausted legs, Evans swam back AGAIN to rescue both the Officer and the 3rd teen girl.
Four people are alive today because a young man put the lives of others before his own.
He truly is a hero. 🎖
*DOJ LAUNCHES INVESTIGATIONS INTO THREE MEDICAL SCHOOLS: NYT
*DOJ PROBES MEDICAL SCHOOLS OVER ADMISSIONS POLICIES: NYT
I hope all my Houston followers will check out Dr Charles Rismyhr. He recently left Houston Methodist to start his own independent practice in the Heights. Unlike most doctors at Houston Methodist, he has common sense and a kind heart.
Don’t fall for the lie that Jews were “safe” under Muslim majority rule.
This day (March 26) in 1839, in Mashhad, Persia (today’s Iran), a Muslim boy—angry over the wages he’d received from a Jewish woman—ran through the streets screaming a blood libel: that the Jews had killed a dog and named it “Hussein” to mock Muslims on their holiest day of mourning.
Thousands of frenzied Muslims stormed the Jewish Quarter, burned the synagogue to the ground, looted and destroyed homes, and murdered 32 Jews.
The survivors were given a stark choice: convert to Islam or die. The entire community chose survival. They outwardly became Muslims.
For the next century, the Mashhadi Jews lived a double life—publicly “new Muslims,” privately observing Shabbat, circumcision, kosher laws, and Jewish holidays behind closed doors, at constant risk of discovery and death.
Best health wishes and prayers for my friend and colleague " Kahn MD, FACC">@drjkahn for his heart valve surgery today. Read his inspiring words for good health introduction to my book. 📕
#HealthIsNumberOne
https://a.co/d/0hnw4LvZ
I’m ready for a different solution
The @US_FDA CDER just approved a new treatment for Hunter Syndrome.
I discuss what Hunter Syndrome is, the data the approval was based on, the post marketing requirement and what this means for families who have children with the disease.
For more info👇
https://www.fda.gov/news-events/press-announcements/fda-approves-drug-treat-neurologic-manifestations-hunter-syndrome
loved her work but this is really disappointing. i hope she can clear this up
We need to empower dental hygienists to open their own businesses -- or to work for a corporation offering this service -- where they just do ultrasonic descaling and cleaning all day long for like $50/person (perhaps less in poorer parts of the country).
Last year, when I was in Morelia, Michoacán, I saw a massive dental clinic on the main street advertising ultrasonic cleanings for less than $10. In and out, in and out, in and out. If I hadn't just gotten my teeth cleaned in Guadalajara, I would have popped in.
In pretty much any other country, you can just go to a dentist and ask them to give you a cleaning -- they won't force you to cough up a new patient fee and submit to outrageously expensive x-rays. They'll take $50 (often less) from you and clean your teeth.
I've paid $35 in Paris, $40 in Mexico, $25 in Guatemala, $60 in Slovenia -- you get the idea.
In the United States, that option basically doesn't exist.