A new, large senior living community is planned in the suburban community of Riverside.In anticipation of a growing need for stroke services, Riverside Community Hospital decided to expand its neurology staff.

The Hospital approached Dr. Headly, who practiced neurology and was a director of a stroke program in a larger, urban area, about becoming an employee of the Hospital to head its stroke program.

Dr. Headly indicated that she would be interested, but she would require compensation 15% above her current compensation.National compensation surveys indicated that the compensation requested by Dr. Headly would exceed fair market value for her services.

However, because the Hospital anticipated significant additional hospital revenues from of the patients Dr. Headly likely would refer to the Hospital for inpatient and outpatient services, the Hospital decided to pay Dr. Headly the requested amount of compensation.

How does the Stark Law apply to the employment arrangement between the hospital and Dr Headly?

Does the proposed arrangement implicate the federal anti kickback statue?