Ultrasound is listed as one of the "designated health services" in the Stark regulations. The regulations reflect CMS's interpretation that Stark encompasses any entity that provides designated health services, without qualifications or limits. Individual physicians or groups of physicians are considered "entities" when they refer patients to themselves or among themselves. An allowable exception applies to group practices, but your financial arrangement would not meet the criteria for this.
As an alternative, you might want to seek half-time employment for your radiology technician in some other office or employ the tech under a job-share arrangement.
