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CMS Re-proposes Ban on Per-Click Fees for Space and Equipment Leases under Stark

In the CY 2017 Medicare Physician Fee Schedule (CY 2017 MPFS), the Centers for Medicare & Medicaid Services (CMS) issued proposed updates to the physician self-referral law (Stark law). The primary Stark law update focused on...more

District Court Issues First Decision Interpreting ACA's 60-day Rule

The first case to interpret when the clock begins to run on the “60-Day Rule” did not go well for health care providers. On August 3rd, the Southern District of New York rejected defendants HealthFirst, Inc.’s and Continuum...more

Recent CMS Guidance Partially Lifts Veil on Stark Self-referral Disclosure Protocol

In 2012, the Centers for Medicare and Medicaid (CMS) issued much-anticipated guidance on the Self-Referral Disclosure Protocol (SRDP) through its publication of thirteen settlements and its statutorily-mandated “Report to...more

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