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In Potomac Valley Orthopeadic Associates v. Maryland State Board of Physicians, the court upheld the State Board of Physician's interpretation of the Maryland self-referral prohibition.

In Potomac Valley Orthopeadic Associates v. Maryland State Board of Physicians, the court upheld the State Board of Physician's interpretation of the Maryland self-referral prohibition. However, in the New Jersey Garcia and Endo Surgi cases, both courts rejected the NJ Board of Medical Examiner's interpretation of the Codey Law.

Can these cases can be reconciled with one another?

Should the courts should be deferential to regulatory interpretations of state self-referral prohibitions?

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