What some providers say they find particularly galling about Stark II is that the Centers for Medicare and Medicaid Services' Medicaid/Medicare reimbursement policy is moving toward a “pay for performance” standard. This means that hospitals and others who receive reimbursement from Medicare/Medicaid will be reimbursed only as long as they can prove with data that they meet the standard of care. As Donna Guadagnoli, president, Colorado Alliance for Continuing Medical Education, Denver, says, ...

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