Does Stark legislation apply differently to PAs than to physicians?

The application of Stark to PAs can be confusing. Although PAs may substitute for physicians in many circumstances under the Medicare reimbursement rules, the Stark statute only pertains to physicians. Therefore, questions regarding PAs, their bonuses, compensation packages and the services they provide should be analyzed under the anti-kickback statute and not Stark. The only Stark implication to billing for PA services is whether they are billed incident to the physician or using the PA's own provider number.