85972 ABFC Health Lawyer
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THE ABA HE ALTH L AW SECTION HEALTH LAWYER THE SPECIAL EDITION APRIL 2004 SPECIAL EDITIONSTARK II -PHASE II -THE FINAL VOYAGE Andrew B. Wachler, Esq. Adrienne Dresevic, Esq. Karen K. Harris, Esq. Wachler & Associates, P.C. Royal Oak, MI Introduction On March 26, 2004, the Centers for Medicare and Medicaid Services (“CMS”) issued the long awaited second phase of its final regulations implementiin the Stark II ban on physician referrals to health care entities with which they have financial...