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You recently drafted a professional services agreement for your client, Messy Desk Health System, pursuant to which MDHS engaged a group of gastroenterologists to provide

You recently drafted a professional services agreement for your client, Messy Desk Health System, pursuant to which MDHS engaged a group of gastroenterologists to provide services at the hospital. You took great pains to make sure that the agreement fully complied with the Stark Law. The document was signed by the president of the gastroenterology group, and was sent to MDHS's CEO, but the agreement was lost in a pile of paperwork and the CEO never executed the document. The gastroenterologists began providing services 2 months ago. Will the agreement be found to be out of compliance with Stark?

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