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CMS Improves Stark Advisory Opinion Process

The Centers for Medicare & Medicaid Services (CMS) recently updated its advisory opinion regulations, codified at 42 CFR §§ 411.370 through 411.389, in a final rule issued November 15, 2019. The update liberalizes and...more

OIG Advisory Opinion 19-04: OIG Approves Health Care Directory's Per-Click Fee Structure

In Advisory Opinion 19-04, published September 10, 2019, the Office of Inspector General (OIG) approved an online health care directory operated on a per-click or per-booking fee arrangement. The proposed directory will be...more

CMS Proposes Liberalizing the Stark Advisory Opinion Process

When the Centers for Medicare and Medicaid Services (CMS) sought input on ways to address the undue burdens of the Stark law through a Request for Information (RFI) in June 2018, its anticipated focus was care coordination,...more

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