Mitchell Surface Published in the American Health Lawyers Association's (AHLA) PG Bulletin 

Media Mention  |  AHLA PG Bulletin

Maynard Nexsen Health Care attorney Mitchell Surface was recently published in the American Health Lawyers Association's (AHLA) PG Bulletin. The article was published on April 4, 2024 and entitled “Stark Law Liability on the Rise: How to Spot Suspect Physician Compensation Arrangements”. 

Mitch was selected by the AHLA Fraud and Abuse Practice Group to write this article. View the full article on their site here (log-in required) or by the linked PDF here and below. 


A recent settlement agreement serves as a reminder that significant liability can still stem from a violation of the federal Physician Self-Referral Law (Stark law). In December 2023, Community Health Network Inc. (CHN), an Indianapolis-based integrated health care system, agreed to a $345 million settlement with the Department of Justice (DOJ) to resolve allegations under the False Claims Act related to employment compensation structures alleged to be above fair market value (FMV). The reminder, therefore, is that as hospitals continue to employ physicians, compensation arrangements must be carefully reviewed to ensure FMV so to provide evidence that such arrangements do not “take into account” the value or volume of referrals.

Copyright 2024, American Health Law Association, Washington, DC. Reprint permission granted.

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About Maynard Nexsen

Maynard Nexsen is a full-service law firm with more than 550 attorneys in 24 offices from coast to coast across the United States. Maynard Nexsen formed in 2023 when two successful, client-centered firms combined to form a powerful national team. Maynard Nexsen’s list of clients spans a wide range of industry sectors and includes both public and private companies. 

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Photo of Mitchell Surface Published in the American Health Lawyers Association's (AHLA) PG Bulletin 

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