The Centers for Medicare and Medicaid Services ("CMS") periodically publishes answers to questions submitted by the public relating to the physician referral law, known as the Stark Law, which prohibits a physician from referring patients to an entity for certain designated health services if the physician has a financial relationship with the entity, unless an exception applies. These questions and answers, known as FAQs, are available online. CMS recently expanded the FAQs to address certain issues arising under the Phase III Final Stark Regulations, which were published in September 2007. (Please see theSeptember 13, 2007, issue of the Health Law Update for more information on the Phase III Regulations.) A majority of the new FAQs address the "stand in the shoes" provision added by Phase III, which provides that a physician stands in the shoes of his or her physician organization for purposes of determining whether a direct or indirect financial relationship exists between the physician and the entity furnishing designated health services. For example, one of the FAQs clarifies that a hospital is not considered a physician organization solely by virtue of its employment or retention of physicians. Other FAQs address physician recruitment by hospitals for residents still in training in the hospital's service area and block lease arrangements. The FAQs provide additional guidance relating to CMS' interpretation of the Stark Law and are a useful tool in structuring Stark compliant relationships.