A clinical laboratory has developed a new test that is billable to Federal health care programs, but physicians are not ordering the tests. The clinical laboratory decides it wants to start

A clinical laboratory has developed a new test that is billable to Federal health care programs, but physicians are not ordering the tests. The clinical laboratory decides it wants to start paying the physicians to order the new tests. It thinks it can make these payments through a “medical speaker program.” The amounts paid to the physicians do not represent fair market value. What, if any, laws might be implicated?
A) This has to do with physicians ordering laboratory tests, so the Stark Law would only apply. B) Neither, so long as an arrangement makes good business sense.
C) Potentially both the Stark Law and Anti-Kickback Statute.
D) Only the Anti-Kickback Statute because the laboratory intends to reward the physician’s for their referrals.
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