Health Advisory: CMS Moves Forward with a Modified Disclosure of Financial Relationships Initiative

As discussed in the Inpatient Prospective Payment System (IPPS) 2009 final rule (final rule) published in the August 19, 2008 Federal Register, the Centers for Medicare and Medicaid Services (CMS) is moving forward with its Disclosure of Financial Relationships Report (DFRR) initiative,1 the purpose of which is to assess compliance with the Stark law by requiring surveyed hospitals to provide detailed information about their ownership, investment, and compensation arrangements with physicians. CMS solicited comments last April about a

number of issues relating to the DFRR. Hospitals, physicians, and other healthcare providers and suppliers should pay attention to this initiative whether or not they (or their hospitals)

are among those facilities being asked to complete the survey. Because CMS will use the results from the DFRR to assess compliance with the Stark law, we expect that the survey will not be a self-limiting assessment tool.

Please see full legal update for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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