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Centers for Medicare & Medicaid Services (CMS) Equipment Lease

ArentFox Schiff

Stark Law Fair Market Value Compensation Exception Expanded to Cover Office Space and Equipment Leases and Clarifies Writing...

ArentFox Schiff on

In its first significant Stark Law rulemaking since 2015, the Centers for Medicare and Medicaid Services (CMS) recently issued a new final rule (Final Rule) intending to provide physicians and designated health services (DHS)...more

Roetzel & Andress

2017 Physician Fee Schedule Includes Clarification of Space and Equipment Rental Exception Under Stark Law

Roetzel & Andress on

The Department of Health and Human Services Center for Medicaid and Medicaid Services (“CMS”) recently finalized the Calendar Year 2017 Physician Fee Schedule (“2017 Fee Schedule”), which includes a restatement of a provision...more

Baker Donelson

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

Baker Donelson on

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

Faegre Drinker Biddle & Reath LLP

Same Per-Click Rule, New Rationale

On July 7 CMS issued a proposed rule reaffirming its position that the Stark Law prohibits “per-click” rent payments when the lessor is the one referring the patients to the lessee for the “click,” e.g., the test or...more

Dickinson Wright

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

Dickinson Wright on

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

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