Lannister General Hospital ("Lannister General") is a hospital located in the town of Kings Landing. The CEO of Lannister General is Ty Lannister. Ty Lannister owns 100% of the stock in Lannister General.

Ty has two sons, James and Terry. James owns a company called Blackwater Transport, which provides patient transportation services in Kings Landing. Terry is married to Dr. Susan Stark, a gastroenterologist. They currently live in Winterfell, a town located 1,500 miles north of Kings Landing.

Dr. Stark's skill and reputation make her highly sought after by communities throughout the country. In Kings Landing, Lannister General wants Dr. Stark to serve as the Medical Director of its gastroenterology program, and Maester Physicians Group ("Maester Physicians"), a physician practice, wants to hire her as an employed physician.

After much discussion, Lannister General, Maester Physicians, and Dr. Stark sign a recruitment agreement for Dr. Stark to relocate her practice to Kings Landing and join Maester Physicians. The recruitment agreement states that Lannister General will pay Dr. Stark $100,000 and reimburse Maester Physicians for the cost of certain specialized equipment it must purchase for Dr. Stark. Kings Landing is not in a health professional shortage area, but it does have a documented need for gastroenterologists. After signing the recruitment agreement, Dr. Stark whispers to Terry Lannister that she would have moved to Kings Landing even if Lannister General had not agreed to pay her $100,000.

Dr. Stark also enters an oral employment agreement with Maester Physicians pursuant to which Master Physicians pays her a flat fee of $500,000 per year, plus a bonus of $1,000 for each patient that Dr. Stark successfully saves from poisoning. Both the fee and the per-patient bonus are consistent with fair market value.

After some additional negotiations, Dr. Stark orally agrees to serve as the Medical Director of the Lannister General gastroenterology program. Ty Lannister emails the contract to he, which makes clear that Dr. Stark will be an independent contractor of Lannister General and not an employee. Dr. Stark replies, "Looks good, I will print a copy and sign." However, she forgets to do so before she starts working as the Medical Director

Six months after moving to Kings Landing, Dr. Stark is not seeing very many poisoning patients. This is surprising to her, given what she has heard about Kings Landing. She discusses this with Terry. Terry, in turn, speaks with his brother James. James tells Terry that Blackwater Transport transports all poisoning patients to Tyrell Memorial Hospital, another hospital in Kings Landing. James tells Terry that he will start transporting patients to Lannister General, where Dr. Stark can treat them, in exchange for $100 per patient. Terry agrees. Dr. Stark does not know about this arrangement.

All of the patients in Kings Landing are insured by Medicare or Medicaid.

QUESTION

Identify each financial relationship in the hypothetical. For each relationship, analyze whether the relationship is permissible under both the Anti-Kickback and Stark laws. If additional information is needed to determine whether the relationship is permissible, please identify what additional information is needed and why.