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What to Expect, Part III: Modified AKS Safe Harbor for Personal Services & Management Contracts

The Office of Inspector General’s (“OIG”) new Anti-Kickback Statute (“AKS”) regulations modify the safe harbor for personal services and management contracts (42 CFR § 1001.952(d)) in a manner that allows providers...more

Potential Delay in Long-Awaited Stark Law and Anti-Kickback Statute Rules

A January 20, 2021 memo issued by the Biden Administration may freeze the implementation of the Stark Law and Anti-kickback Statute (“AKS”) final rules that went into effect on January 19, 2021. According to the U.S....more

What to Expect: HHS Issues Final Rules on Stark, AKS & CMP Laws

The U.S. Department of Health and Human Services (“HHS”) recently issued two corresponding final rules amending the implementing regulations of the Physician Self-Referral Law (“Stark Law”), the Anti-Kickback Statute (“AKS”),...more

CMS Issues Guidance to State Medicaid Directors for Adoption of Value-Based Care

On September 15, the Centers for Medicare & Medicaid Services (CMS) issued guidance to state Medicaid directors encouraging states to adopt value-based care (VBC) models for their healthcare systems. Under a VBC model,...more

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