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Physician Fee Schedule Final Rule for Calendar Year 2022 – CMS Cuts Rates and Extends Telehealth

On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) issued its Calendar Year (CY) 2022 Physician Fee Schedule (“PFS”) Final Rule. In this post, we sample some key highlights from the Final Rule. ...more

OIG Publishes Favorable Advisory Opinion Related to the Employment Safe Harbor

In an advisory opinion posted November 10, 2021 (AO 21-15), the Office of the Inspector General of the United States Department of Health and Human Services (OIG) appeared to soften a disturbing position that it had taken in...more

The University of Miami to Pay $22 Million to Settle Medicare False Claims Act Allegations

The U.S. Department of Justice (the “DOJ”) recently settled whistleblower False Claims Act (“FCA”) allegations against The University of Miami (“UMiami”) for $22 million, which resolves claims from three separate lawsuits...more

New Opportunities for Value-Based Care with HHS Finalization of Stark Law, Anti-Kickback Statute, and Civil Monetary Penalties Law...

The Department of Health and Human Services (“HHS”), in collaboration with the Centers for Medicare & Medicaid Services (“CMS”) and the Office of the Inspector General (“OIG”), has issued two final rules clarifying certain...more

CMS Issues Broad Stark Waiver Related to COVID-19

In yet another example of coronavirus-related regulatory dispensation, on March 30, 2020, CMS announced that it will waive penalties for violations of the Stark Law in regard to compensation relationships between physicians...more

HHS Releases Proposed Stark Law, Anti-Kickback Statute, and Civil Monetary Penalties Law Reforms

On October 9, 2019, the Department of Health and Human Services ("HHS") issued proposed changes to the regulations implementing the Physician Self-Referral Law (the "Stark Law"), the Anti-Kickback Statute (the "AKS"), and the...more

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