Marki Stewart

Marki Stewart

Dickinson Wright

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Latest Publications


Analysis of New Timeshare Arrangement Exception to the Stark Law – Part 2

In a previous post, we analyzed the new Timeshare Arrangement exception to the Stark law that CMS proposed and went into effect on January 1, 2016. Here we give an example of how the new timeshare arrangement exception works...more

3/22/2016 - CMS Commercial Leases Equipment Lease Stark Law Timeshare Arrangement

Analysis of New Timeshare Arrangement Exception to the Stark Law – Part 1

On July 15, 2015, the Centers for Medicare & Medicaid Services (CMS) proposed a series of rules that would create new exceptions to the Stark law, in addition to clarifying other provisions of the Stark law. One of the newly...more

3/15/2016 - CMS Exceptions Physicians Stark Law Timeshare Arrangement

CMS To Publish Financial Relationships Between Physicians and Drug Manufacturers Beginning September 2014

Beginning in September 2014, the Centers for Medicare and Medicaid Services (“CMS”) will publish a list of all payments and transfers of value paid by drug manufacturers to physicians and teaching hospitals on a publicly...more

4/24/2014 - Biologics CMS Medical Devices Pharmaceutical Industry Physician Payments Sunshine Act Teaching Hospitals

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