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Physicians Stark Law Self-Referral

Dentons

Ep. 30 – Ensuring Payments to Physicians for Administrative Services Meet a Stark Exception

Dentons on

Providers will often pay physicians for serving in important administrative roles within the organization. Compensation for administrative services can create risk to the organization under multiple laws, including the...more

McGuireWoods LLP

CMS Again Settles Record Stark Self-Disclosures in 2023

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The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2023 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law (the Stark...more

McDermott Will & Emery

Stark Law Changes for 2024: CMS Updates Designated Health Services Code List

McDermott Will & Emery on

On November 29, 2023, the Centers for Medicare & Medicaid Services (CMS) published the 2024 annual update to the designated health services (DHS) Code List. This annual update includes important changes for Medicare providers...more

Bricker Graydon LLP

A Long-Awaited Change: OIG Updates its Compliance Program Guidances

Bricker Graydon LLP on

From 1998-2008, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) published compliance program guidelines for various industries in the Federal Register....more

Katten Muchin Rosenman LLP

CMS Settled a Record Number of SRDPs in 2022

The Centers for Medicare and Medicaid Services (CMS) recently updated the publicly available information regarding the Self-Referral Disclosure Protocol (SRDP) settlements to include aggregate settlement data from calendar...more

McDermott Will & Emery

Congress Adds AKS and Stark Law Exceptions for Certain Wellness Programs

As a part of the Consolidated Appropriations Act, 2023 (CAA), Congress passed new exceptions to the Physician Self-Referral Law (Stark Law) and the federal Anti-Kickback Statute (AKS) allowing certain healthcare entities to...more

Epstein Becker & Green

Hidden in Plain Sight: Lesser-Known Exceptions Recently Adopted by Congress to the Federal Physician Self-Referral Law and...

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At the end of 2022, Congress enacted the Consolidated Appropriations Act of 2023 (“CAA”), for which there has been much fanfare.   As it relates to health care, this legislation included provisions addressing issues such...more

Robinson+Cole Health Law Diagnosis

Stark Settlement Targeting Hospital and Physicians a Reminder for Health Care Organizations

On March 29, 2023, the Department of Justice’s (DOJ) Office for the Eastern District of Michigan announced a notable set of three settlements (collectively, the Settlement) in excess of $69 million dollars total with a...more

McDermott Will & Emery

Healthcare Regulatory Check-up Newsletter | January 2023 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights significant regulatory activity and developments occurring in January 2023, including several criminal and civil enforcement actions related to the federal...more

Baker Donelson

CMS Approves New Group Information Form under Self-Referral Disclosure Protocol

Baker Donelson on

Following the comment period that ended on August 8, 2022, the Centers for Medicare and Medicaid Services (CMS) recently finalized changes to the Self-Referral Disclosure Protocol (SRDP) for physician practices to disclose...more

Maynard Nexsen

Stark Law Group Practice Requirements

Maynard Nexsen on

The Centers for Medicare & Medicaid Services (CMS) published updates to the CMS Voluntary Self-Referral Disclosure Protocol (SRDP) on January 23, 2023. The SRPD is the CMS process for Medicare providers and suppliers to...more

Foley & Lardner LLP

Stark Law Changes: Hospitals Need to Revisit Physician Compensation Arrangements

Foley & Lardner LLP on

Based on recent changes and clarifications made by the Centers for Medicare and Medicaid Services (CMS) in the Federal Physician Self-Referral Law (commonly known as the “Stark Law”), hospitals and health systems need to...more

Dickinson Wright

[Webinar] Safeguarding Your Practice: 2022 Fraud and Abuse Updates - November 10th, 1:00 pm - 2:00 pm EST

Dickinson Wright on

This presentation will provide an update on significant changes in significant cases related to the Stark Law, Civil Monetary Penalties Law, and the Anti-Kickback Statute....more

Baker Donelson

CMS Requests Comments on Proposed Changes to Stark Law Self-Referral Disclosure Protocol Forms

Baker Donelson on

On June 9, 2022, the Centers for Medicare and Medicaid Services (CMS) solicited comments to proposed changes to the Self-Referral Disclosure Protocol (SRDP) for physician practices disclosing group practice noncompliance....more

Bass, Berry & Sims PLC

CMS Proposes New Stark Law Exception for Rural Emergency Hospitals

Bass, Berry & Sims PLC on

On July 15, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System proposed rule...more

McGuireWoods LLP

CMS Considers Streamlined Physician Group Stark Law Self-Disclosures

McGuireWoods LLP on

On June 9, 2022, the Centers for Medicare & Medicaid Services announced an opportunity for the public to comment through Aug. 8, 2022, on its voluntary self-referral disclosure protocol (SRDP). The voluntary SRDP is a way to...more

Benesch

CMS Clarifies Expansion of Physician-Owned Hospital’s “Unlicensed” Observation Beds Under Stark “Whole Hospital” Exception

Benesch on

The Centers for Medicare & Medicaid Services (CMS) recently issued an advisory opinion under the federal physician-self referral law (the “Stark Law”) (Advisory Opinion No. CMS-AO-2021-2) (the “Advisory Opinion”) clarifying...more

Goodwin

Changes to Stark Law Special Compensation Rules for Group Practices Go into Effect on January 1, 2022

Goodwin on

The final rules regarding special compensation under 42 U.S.C. § 1395nn, the Physician Self-Referral or Stark Law, go into effect on January 1, 2022 and will require many physician group practices to modify their compensation...more

Proskauer - Health Care Law Brief

OIG Publishes Favorable Advisory Opinion Related to the Employment Safe Harbor

In an advisory opinion posted November 10, 2021 (AO 21-15), the Office of the Inspector General of the United States Department of Health and Human Services (OIG) appeared to soften a disturbing position that it had taken in...more

Proskauer - Health Care Law Brief

CMS Corrects Inadvertent Omissions in Recent Stark Law Regulatory Amendments, Clarifies Reach of the Prohibition Related to...

Earlier this month, the Centers for Medicare and Medicaid Services (CMS) released its final rules for the 2022 Medicare Physician Fee Schedule (PFS Final Rule) and 2022 Medicare Hospital Outpatient Prospective Payment System...more

Davis Wright Tremaine LLP

Physician Group Practice Alert: New Stark Requirements on Compensation Models Take Effect January 1, 2022

On December 2, 2020, the Centers for Medicare & Medicaid Services (CMS) published the final "Sprint Regulations," reinterpreting key aspects of the federal physician self-referral or "Stark" law. Most of the Sprint...more

Robinson+Cole Health Law Diagnosis

CMS Issues Advisory Opinion Clarifying Physician Self-Referral Law Group Practice Structure

In June 2021, the Centers for Medicare and Medicaid Services (CMS) issued a notable interpretation of the Physician Self-Referral Law (aka the Stark Law) in Advisory Opinion No. CMS-AO-2021-01 (Advisory Opinion) regarding...more

Nelson Mullins Riley & Scarborough LLP

What the New CMS Advisory Opinion Means for Providers

The Centers for Medicare & Medicaid Services (CMS) has issued Advisory Opinion No. CMS-AO-2021-01 on whether a wholly-owned physician practice that provides designated health services (“DHS”) through one or more wholly-owned...more

Sheppard Mullin Richter & Hampton LLP

CMS Proposes to Revise, Again, the Stark Law’s Definition of “Indirect Compensation Arrangement”: What Was Old is New Again

On July 13, 2021, the Centers for Medicare and Medicaid Services (“CMS”) released a Proposed Rule that proposes to amend certain regulations implementing the Physician Self-Referral Law, otherwise known as the “Stark Law”....more

McGuireWoods LLP

Stark Law 2020 Settlements Return to Pre-2019 Trend

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The Centers for Medicare & Medicaid Services (CMS) recently announced 2020 settlements concerning past violation or potential violations of the physician self-referral law (the Stark Law) and the number and value of such...more

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