Valuation Implications On November 20, 2020, the Centers for Medicare & Medicaid Services (CMS) issued a final rule to modernize and clarify the Stark Law. The Stark Law governs those physicians (or their immediate family members) who have a financial relationship with an entity, and prohibits those individuals from making Medicare referrals to those entities for the provision of designated health services (DHS).  Notably, the law contains a large number of exceptions, which describe ownership interests, compensation arrangements, and forms of remuneration to which the Stark Law does not apply. This article will focus on the definitional changes to commercial…