Q&A: In-house referrals

Q: I plan to work for a primary care practice owned by a radiologist who insists that any radiological procedures I order be referred to him and handled in-house. Would this violate Stark regulations?

A: Not as long as you're a bona fide employee of the practice. Requiring "in-system" referrals is legitimate under the employment and personal services exceptions of the regulations. Those exceptions aside, patients should have the right to overrule that requirement if they prefer to have radiological services performed elsewhere.