Concurrent with the termination of the COVID-19 Public Health Emergency, various regulatory flexibilities will also come to an end, including the blanket waivers to the Stark Law and related enforcement discretion under the...more
Powerfully illustrating the efforts of the US Department of Health and Human Services (HHS) to transform the US healthcare system to a value-based model, the Office of the Inspector General (OIG) and the Centers for Medicare...more
11/25/2020
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Healthcare Reform ,
OIG ,
Rulemaking Process ,
Safe Harbors ,
Stark Law ,
Value-Based Care
The Centers for Medicare & Medicaid Services and the US Department of Health and Human Services Office of Inspector General have provided additional guidance and clarification on the application of Stark Law blanket waivers...more
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
Highlighting the US Department of Health and Human Services’ (HHS) efforts to transform the US healthcare system to a value-based model, the Office of the Inspector General (OIG) and the Centers for Medicare and Medicaid...more
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
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
A new report suggests that the Stark law is obsolete in new payment models.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
7/7/2016
/ Affordable Care Act ,
AHLA ,
Alternative Payment Models (APM) ,
Anti-Kickback Statute ,
Civil Monetary Penalty ,
False Claims Act (FCA) ,
Fraud Abuse and Waste ,
Health Care Providers ,
Legislative Agendas ,
Medicare ,
Medicare Access and CHIP Reauthorization (MACRA) ,
Physicians ,
Repeal ,
Stark Law
The new clarifications suggest a more lenient CMS, but providers shouldn’t compromise their compliance standards.
Throughout the halls of hospitals’ legal and compliance departments, people have been talking....more
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
7/10/2015
/ ACOs ,
Alternative Payment Models (APM) ,
Centers for Medicare & Medicaid Services (CMS) ,
Client Referrals ,
Comment Period ,
Exceptions ,
FQHC ,
Healthcare ,
Hospitals ,
Medicaid ,
Medicare ,
Physician Fee Schedule ,
Physicians ,
Proposed Regulation ,
Rural Health Care Providers ,
Stark Law
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
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