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Key Telehealth Provisions in the Calendar Year 2022 Physician Fee Schedule Final Rule

On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2022 Medicare Physician Fee Schedule (PFS) final rule (Final Rule), which finalized several noteworthy policies related...more

Regulatory Sprint: Understanding the Impact on the Stark Law, Anti-kickback Statute, and Value-based Arrangements

The Department of Health and Human Services has released extensive and significant revised final rules governing the Physician Self-Referral Law (the Stark law) and the Medicare Anti-Kickback Statute (AKS) in furtherance of...more

Proposed 2021 Physician Fee Schedule to Expand Telehealth and Scope of Services for Nonphysician Practitioners and Pharmacists

On August 3, 2020, CMS issued proposed rules announcing and soliciting public comments on new policy changes for Medicare payments under the Calendar Year (CY) 2021 Physician Fee Schedule (PFS) and other Medicare Part B...more

Coronavirus: Expanded Coverage of Medicare Telehealth Services During Pandemic

The Coronavirus Preparedness and Response Supplemental Appropriations Act, which was enacted on March 6, 2020, allows the Secretary of the United States Department of Health and Human Services (HHS) to waive certain...more

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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