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CMS Proposes Additional Revisions to the 60-Day Rule

The Centers for Medicare & Medicaid Services has issued its Calendar Year 2025 Medicare Physician Fee Schedule Proposed Rule, scheduled for publication in the Federal Register on July 31, 2024. In response to industry...more

OIG Approves Consultant’s Provision of Gift Cards to Physician Practices

The US Department of Health and Human Services Office of Inspector General (OIG) published favorable Advisory Opinion No. 23-15 on January 3, which concluded that a consultant’s proposal to provide gift cards to existing...more

OIG Approves Net Profit–Based Bonuses for Employed Physicians

The US Department of Health and Human Services Office of Inspector General (OIG) recently released Advisory Opinion No. 23-07, in which OIG approved a proposed arrangement to pay employed physicians bonuses based on net...more

CMS Releases Physician Fee Schedule Proposed Rule, Continuing Emphasis on Equity and Value-Based Care

The Centers for Medicare & Medicaid Services on July 7 released its proposed rule for the Medicare physician fee schedule for Calendar Year 2023. Among other updates, the proposed rule contains significant programmatic...more

Stark Law and Anti-Kickback Statute Enforcement: For HHS, It’s Not Business as Usual

The US Department of Health and Human Services recently announced the use of blanket waivers for healthcare providers under the Stark Law, and its Office of Inspector General noted it will exercise enforcement discretion in...more

Is Stark Law Reform or Repeal in the Offing?

The Centers for Medicare & Medicare Services has issued a request for information seeking public comment on how to address the undue regulatory impact and burden of the physician self-referral law, commonly known as the Stark...more

Provider-Based Rule and Stark—Is Joint Compliance Impossible in 2017?

The Centers for Medicare & Medicaid Services (CMS) will be putting hospitals in an untenable position if recent proposed rulemaking is implemented as is. In its proposal for acting on legislation reducing payments to new,...more

Senate Finance Committee Examines Repeal of the Stark Law

A new report suggests that the Stark law is obsolete in new payment models. On June 30, the US Senate Committee on Finance (the Committee) released the report Why Stark, Why Now? Suggestions to Improve the Stark Law to...more

CMS Releases 2016 Physician Fee Schedule

Major changes to Stark law are ahead, including new exceptions for timeshare arrangements and employment of NPPs. The Centers for Medicare & Medicaid Services (CMS) released a proposed rule on July 8 for the 2016...more

The Three “Hows” Of Physician Compensation

New care delivery models and healthcare reimbursement trends are heating up the market for hospital employment of physicians yet again, but does a productivity-based compensation model still work in this environment?...more

Final Sunshine Act Arrives: Now the Hard Part

The Centers for Medicare and Medicaid Services (CMS) issued the final regulations on the U.S. Sunshine Act on February 8, 2013. Transparency Reports and Reporting of Physician Ownership or Investment Interests, 78 Fed. Reg....more

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