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Self-Referral Disclosure Protocol Stark Law

McDermott Will & Emery

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

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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

Epstein Becker & Green

Physicians Beware! Groups Providing DME, Prosthetic Devices, and Other Medical Supplies to Their Medicare Patients Risk Violating...

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When the COVID-19 Public Health Emergency (“PHE”) ended on May 11, 2023, many physician groups furnishing certain medical equipment, devices, and/or supplies to their Medicare patients became in violation of the federal...more

McDermott Will & Emery

Top Takeaways | 2023 Physician Practice Management & ASC Symposium 2023 | Fraud & Abuse Risk Mitigation and Enforcement Trends

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In this session, McDermott Will & Emery Partners Denise Burke, Tony Maida and Monica Wallace discussed top issues and enforcement trends that physician practice management companies (PPMs) and ambulatory surgery centers...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

Sheppard Mullin Richter & Hampton LLP

CMS Streamlines Stark Law Self-Referral Disclosure Protocol (SRDP)

Effective March 1st, certain providers choosing to self-disclose Stark Law violations must use forms updated by the Centers for Medicare & Medicaid Services (“CMS”)....more

Bass, Berry & Sims PLC

CMS Tweaks Voluntary Self-Referral Disclosure Protocol, Adds New Form for Group Practice Disclosures

Bass, Berry & Sims PLC on

On January 23, the Centers for Medicare & Medicaid Services (CMS) released revisions to its Voluntary Self-Referral Disclosure Protocol (SRDP), an important mechanism through which providers may disclose actual or potential...more

ArentFox Schiff

New Stark Exception Provides Additional Flexibility for Limited Financial Arrangements With Physicians

ArentFox Schiff on

As part of its recent rulemaking process, the Centers for Medicare and Medicaid Services (CMS) finalized a new exception to the Physician Self-Referral Law (the Stark Law) to protect arrangements where limited remuneration is...more

Davis Wright Tremaine LLP

CMS Sprints to Overhaul Stark

With the benefit of more than three decades of rulemaking and hundreds of submissions under the Self-Referral Disclosure Protocol, CMS has seized the opportunity in the final Sprint Regulations to adopt a number of...more

Hinshaw & Culbertson - Health Care

Blanket Waiver on Stark Law Sanctions Provides Limited Relief in Light of Pandemic

On March 30, 2020, the Secretary of the U.S. Department of Health and Human Services issued a "blanket waiver" impacting the physician self-referral law known as the Stark Law. The blanket waiver—which is retroactively...more

K&L Gates LLP

K&L Gates Triage: COVID-19 Stark Waivers

K&L Gates LLP on

In this week’s episode, Mary Beth Johnston, Carolyn Merritt and Leah Richardson discuss the ways in which the Centers for Medicare and Medicaid Services’ (CMS) response to the ongoing COVID-19 outbreak is easing certain...more

Brownstein Hyatt Farber Schreck

HHS Issues Blanket Waivers of Stark Law to Address COVID-19 Pandemic

On March 30, 2020, the Secretary of the United States Department of Health and Human Services (“HHS”) exercised his authority to waive certain Medicare requirements during an emergency and issued blanket waivers of sanctions...more

Polsinelli

Analyzing the Proposed 2019 Stark Reforms

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The United Stated Department of Health and Human Services (“HHS”) published a notice of proposed rulemaking (NPRM) containing proposed changes to the Physician Self-Referral Law (“Stark Law,” or “Stark”) on October 17, 2019....more

Seyfarth Shaw LLP

CMS’ Proposed Stark Rule Change and Guidance on “The Big Three”: Fair Market Value, Commercial Reasonableness, and Taking Into...

Seyfarth Shaw LLP on

As part of a larger “Regulatory Sprint to Coordinated Care” the Centers for Medicare & Medicaid Services (CMS) of the U.S. Department of Health & Human Services (HHS) recently issued a proposed rule aimed at modernizing and...more

Baker Donelson

CMS Advisory Opinion 2019-01 Approves Physician-Owned Hospital's Plan to Use Dormant Remote Operating Rooms

Baker Donelson on

A physician-owned hospital with operating rooms at a second campus that have been inactive since before March 23, 2010 received approval from CMS to include such spaces within the hospital's aggregate capacity limits,...more

Akerman LLP - Health Law Rx

Possible Changes to Stark Law in 2019

Last summer The Centers for Medicare and Medicaid Services (CMS) solicited input on potential amendments to the federal Physician Self-Referral Law (the Stark Law)....more

Ruder Ware

Reminder: New Voluntary Self-Referral Disclosure Effective June 1

Ruder Ware on

As discussed in a previous blog, beginning on June 1, 2017, health care providers of services and suppliers wanting to voluntarily disclose actual or potential violations of the Stark Law must follow a new process finalized...more

Polsinelli

Stark Law: What Providers Should Know About New CMS Form

Polsinelli on

The Centers for Medicare and Medicaid Services (CMS) has finalized Form CMS-10328 (the SRDP Form), a new OMB-approved information collection instrument that must be used by providers and suppliers utilizing the Stark Law...more

Baker Donelson

CMS Finalizes New SRDP Disclosure Form and Process

Baker Donelson on

Parties disclosing actual or potential violations of the Stark law will use a new series of forms under CMS's Voluntary Self-Referral Disclosure Protocol (SRDP) process as of June 1, 2017. According to CMS, the new forms...more

Baker Donelson

CMS Announces Plans to Streamline the Stark Self-Referral Disclosure Protocol

Baker Donelson on

On May 6, 2016, CMS published a notice (Notice), required under the Paperwork Reduction Act (PRA), seeking public comment on its plans to revise the information collected under the Medicare Self-referral Disclosure Protocol...more

McDermott Will & Emery

CMS Finalizes Stark Law Amendments

McDermott Will & Emery on

On November 16, 2015, the Centers for Medicare and Medicaid Services (CMS) published the 2016 Medicare Physician Fee Schedule final rule with comment period in the Federal Register at 80 Fed. Reg. 70,886, which includes a...more

Baker Donelson

Limited Modifications in Final ACO Fraud and Abuse Waivers Most Notably Include Cut of Gainsharing CMP Waiver

Baker Donelson on

Nearly four years after publishing their joint interim final rule with comment period, effective November 2, 2011 (IFC), the OIG and CMS (Agencies) have finalized the waivers of various fraud and abuse laws in the context of...more

McDermott Will & Emery

Huge Stark Law Hospital Settlements and Physician Culpability - The New Normal Post-Tuomey?

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After the federal government’s victory against Tuomey Hospital, we have seen an increasing number of large False Claims Act (FCA) settlements with hospitals involving Stark Law allegations. Relators are even citing, as...more

K&L Gates LLP

Potential Stark Changes Ahead

K&L Gates LLP on

On July 15, 2015, the Centers for Medicare and Medicaid Services (“CMS”) published proposed regulations governing policies and payments made under the Physician Fee Schedule for calendar year 2016 (the “Proposed Rule”). In...more

Baker Donelson

Stark Regulations: Technical Revisions

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The proposed Physician Fee Schedule for CY 2016 includes multiple technical revisions to the regulations implementing the Stark law. These revisions appear to be designed to provide greater clarity and flexibility with...more

Polsinelli

Fourth Circuit Upholds $237 Million Stark Judgment

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On July 2, 2015, the United States Court of Appeals for the Fourth Circuit affirmed a $237 million judgment against Tuomey Healthcare System, Inc. (“Tuomey”), in a federal False Claims Act (“FCA”) case arising out of...more

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