Earlier this year, the U.S. Department of Health and Human Services (HHS) and Centers for Medicare and Medicaid Services (CMS) issued new rules modernizing the Stark and Anti-Kickback laws. There are now less than two months until significant changes to the federal physician self-referral law (Stark Law or Stark) "group practice" definition special compensation rule go into effect on Jan. 1, 2022. Among other things, these changes revise the rule related to "overall profits" to prohibit pooling and distributing profits or productivity bonuses from designated health services (DHS), such as in-office laboratory or imaging services, on a service-by-service basis. This practice is sometimes referred to as "split pooling."