THE ABA HE ALTH L AW SECTION HEALTH LAWYER THE SPECIAL EDITION JANUARY 2001 SPECIAL EDITIONSTARK II FINAL RULE -PHASE I A Kinder and Gentler Stark? Andrew B. Wachler and Phyllis A. Avery Wachler & Associates, P.C. Royal Oak, MI Introduction On January 4, 2001, the Health Care Financing Administration (“HCFA”) issued the first part of its final regulations implementing the Stark II ban on physiciia self-referral. 66 Fed. Reg. 856 (2001). In response to numerous complaints that the Stark II...