CAH CFO-Administrator Forum: Regulatory Insights: Executing CAH Physician JVs and Other Legal Developments

On October 29, 2021, EqualizeRCM sponsored a forum for CFOs and CEOs of Critical Access Hospitals, where Colin Luke, JD Principal, and Fletcher Brown, JD, Principal, with Waller Lansden Dortch & Davis, LLP presented “Regulatory Insights: Executing CAH Physician JVs and Other Legal Developments.”

On October 29, Colin Luke, JD, Principal and Fletcher Brown, JD, Principal, with Waller Lansden Dortch & Davis, LLP (Waller) provided virtual education on Critical Access Hospital physician joint ventures as a growth strategy and new updates to Stark Law. The 90-minute Forum also featured roundtable discussion by many CEO/CFO participants. The group discussion was facilitated by Forum Moderators Chris Ekrem, FACHE, VP Hospital Financial Operations at EqualizeRCM and Darya Khripkova, EVP Operations at EqualizeRCM.

EqualizeRCM is pleased to sponsor another relevant educational session with expert speakers for small hospital administrators and CFOs. The 10/29 Forum focused on the following:

  1. Under Arrangement Joint Venture Opportunities for Surgical Services: Qualifying rural areas only.
  2. Definitions of Services for Rural Areas Only: Any area not listed as a Metropolitan Statistical Area by the OMB.
  3. 2021 Stark Developments: Final rule was effective on January 19, 2021.
  4. New Stark Definitions:
    1. Commercially reasonable.
    2. Fair market value for compensation, space and equipment.
    3. Volume or value of referrals or other business generated.
  5. New Value Based Opportunities
  6. Special Rule for Payment Discrepancies
  7. Clarification for Physician DHS Pools
A written summary of the 10/29 Forum is available by contacting Chris Ekrem at

Be sure and visit us online at to learn more about future educational events. Also, visit us on our LinkedIn page at to stay connected with your professional peers.

The CAH CFO-Administrator Forum, is organized by EqualizeRCM, a leading proponent for Community Health organizations. The CAH Forum seeks to provide Financial Administrators of rural health facilities an opportunity to participate in focused events, share insightful ideas, discuss challenges and solutions, but most importantly collaborate and communicate with like-minded professionals in the industry. Learn more by visiting or contacting

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