Stark Law, Anti-Kickback Statute, OIG

CMS and OIG Propose Changes to the Electronic Health Records Exception and Safe Harbor

by Thompson Coburn LLP on 4/25/2013

On April 10, 2013, the Centers for Medicare & Medicaid Services (“CMS”) and the Department of Health and Human Services Office of Inspector General (“OIG”) published parallel proposed rules revising, respectively, the Stark...more

The Top 10 Things You Need To Know About The OIG’S Revised Self-Disclosure Protocol

by Laurence Freedman, Laura Laemmle-Weidenfeld | Patton Boggs LLP on 4/23/2013

On Wednesday, April 17, 2013, the Department of Health and Human Services’ Office of Inspector General (OIG) released an updated Self-Disclosure Protocol (SDP) governing the process by which health care providers can...more

OIG Unveils Updated Self-Disclosure Protocol

by George Breen, Jason Christ, Anjali Downs, Jennifer Goodwin, David Matyas, Deepa Selvam, Carrie Valiant | Epstein Becker & Green, P.C. on 4/23/2013

In 1998, the Department of Health and Human Services' Office of Inspector General ("OIG") published the Self-Disclosure Protocol ("SDP"), which provides a mechanism through which health care providers may voluntarily report...more

OIG and CMS Issue Proposals to Extend Safe Harbor and Exception for EHR Donations

by Darby C. Allen, Donna S. Clark | BakerHostetler on 4/22/2013

In the April 10 Federal Register, two agencies within the U.S. Department of Health and Human Services published proposed rules that many healthcare providers have been anxiously awaiting affecting donations of electronic...more

CMS and OIG Issue Proposed Rules Modifying the Stark Exception and Anti-Kickback Safe Harbor for Donation of EHR

by C. Frederick Geilfuss II, Shilpa Patel, Richard Rifenbark, Donald H. Romano | Foley & Lardner LLP on 4/19/2013

On April 10, 2013, the Centers for Medicare and Medicaid Services (CMS) and the Office of the Inspector General of the U.S. Department of Health and Human Services (OIG) each published proposed rules in the Federal Register...more

HHS Extends Sunset Date for Stark Exception and Anti-Kickback Safe Harbor for EHR Donations

by Daniel F. Gottlieb | McDermott Will & Emery on 4/19/2013

The Centers for Medicare & Medicaid Services and the U.S. Department of Health and Human Services issued proposed rules that would extend the sunset date for the Stark Law exception and the federal Anti-Kickback Statute safe...more

HHS OIG Issues Revised Self-Disclosure Protocol

by Holly Barker, Albert Shay, Howard Young | Morgan Lewis on 4/18/2013

OIG touts substantial benefits of disclosing, provides greater detail for different types of disclosures, and captures 15 years of OIG Self-Disclosure Protocol experience....more

CMS, OIG Propose to Extend EHR Stark Exception and Anti-Kickback Safe Harbor

by King & Spalding on 4/16/2013

On April 10, 2013, CMS and the HHS Office of Inspector General (OIG) each published proposed rules to extend the sunset dates for the Stark exception and anti-kickback statute safe harbor permitting donations of EHR software...more

CMS and OIG Propose Extension of Federal Stark Exception and Anti-Kickback Safe Harbor for Electronic Health Record Donations

by Ropes & Gray LLP on 4/11/2013

On Wednesday, April 10, 2013, the Centers for Medicare & Medicaid Services (“CMS”) and the Office of the Inspector General (“OIG”) of the Department of Health and Human Services published complementary proposed rules in the...more

The Healthcare Industry And The Voluntary Disclosure Process

by Michael Volkov on 2/21/2013

It is always important to consider how different parts of the government handle voluntary disclosures. The FCPA enforcement initiative has been largely the result of the voluntary disclosure process, and the government...more

OIG Advisory Opinion Sheds Light On Pay-For-Performance Relationships Between Hospitals And Physicians

by Darby C. Allen, Donna S. Clark | BakerHostetler on 1/20/2013

On January 7, 2013, the HHS OIG released Advisory Opinion 12-22 concerning a rural hospital's (Hospital) proposal to pay a cardiology group (Group) a performance bonus for achieving certain patient service, quality and cost...more

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Stark Law › Anti-Kickback Statute › OIG