In two prior columns, we have cautioned that contractual joint ventures and lease arrangements are under increased scrutiny, both by the US Department of Health and Human Services Office of Inspector General (OIG) under the federal antikickback statute and by state enforcement agencies under state fraud and abuse laws [ 1 Travis N.L. Chananie S.J. Finnegan J.H. The stark reality about shared nuclear medicine imaging equipment leasing arrangements after January 1, 2007. J Am Coll Radiol. 2006; 3: 910-913 Abstract Full Text Full Text PDF PubMed Scopus (1) Google Scholar , 2 Travis N.L. Chananie S.J. Gulick S.L. Legitimate lease arrangement or suspect joint venture?. J Am Coll Radiol. 2007; 4: 353-355 Abstract Full Text Full Text PDF PubMed Scopus (3) Google Scholar ]. Now the Centers for Medicare and Medicaid Services (CMS) is paying attention and is currently considering how such arrangements should be judged under the federal physician self-referral law (commonly referred to as the Stark law 1 The Stark law prohibits a physician (and immediate family members) from making any referrals of Medicare “designated health services” (DHS) to an entity with which the physician has a direct or indirect financial relationship, unless a statutory or regulatory exception is met. Radiologic services, including nuclear imaging and other modalities, are covered DHS. ).